Republic Of The Philippines REGIONAL TRIAL COURT 11" Judicial Region Branch 34 Panabo City REINFREDO M. ABAYHON, APPEALED CASE NO. Beamaff Appel, AC-SCC 08-2017 -versus- LEAD EXPORTS AND AGRO-DEVELOPMENT CORPORATION, SBelndant Appell APPELLANT'S MEMORANDUM COMES NOW plaintiff-appellant, through counsel, and to this Honorable Court, most respectfully state: Since time immemorial, land has always been a commonly serious source of dispute between individuals, entities, states and even among civilizations. But what sets this case apart from the others is the fact that the Property subject is duly titled in the name of the complainant and no other. As it is aptly said,we have ruled that a tenant cannot, in an action involving the possession of the leased premises, controvert the title of his landlord or assert any rights adverse to that title. Neither can he set up any inconsistent right to change the relation existing between himself and his landlord” (Manuel v. Court of Appeals, 199 SCRA 603 [1991]). PREFATORY STATEMENT This is an appeal pursuant to Rule 40 of the Revised Rules on Civil Procedure seeking the nullification and/or reversal of the decision of the 1* Municipal Circuit Trial Court of Carmen ~ Sto. Tomas - Braulio E. Dujali, 11" judicial Region, on the