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MURPHY
CANYON ACQUISITION CORP.

4995
Murphy Canyon Road, Suite 300

San
Diego, CA 92123

November
23, 2022

William
Demarest

Isaac
Esquivel

Division
of Corporation Finance

Office
of Real Estate & Construction

U.S.
Securities Exchange Commission

100
F Street, NE

Washington,
D.C., 20549

  Re:
  Murphy Canyon Acquisition Corp.

  Form 10-K for the year ended December 31, 2021 Filed

  March 29, 2022

  File No. 001-41245

Dear
Mr. Demarest and Mr. Esquivel:

Murphy
Canyon Acquisition Corp. (“we” or the “Company”) submits this letter in response to the comment from the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated November
21, 2022, relating to the above referenced annual report of the Company.

In
this letter, we have recited the comment from the Staff in bold type and have followed each comment with the Company’s response
in ordinary type.

Form
10-K for the year ended December 31, 2021

General

1. With
                                            a view toward disclosure, please tell us whether your sponsor is, is controlled by, or has
                                            substantial ties with a non-U.S. person. If so, please revise your disclosure in future filings
                                            to include disclosure that addresses how this fact could impact your ability to complete
                                            your initial business combination. For instance, discuss the risk to investors that you may
                                            not be able to complete an initial business combination with a U.S. target company should
                                            the transaction be subject to review by a U.S. government entity, such as the Committee on
                                            Foreign Investment in the United States (CFIUS), or ultimately prohibited. Disclose that
                                            as a result, the pool of potential targets with which you could complete an initial business
                                            combination may be limited. Further, disclose that the time necessary for government review
                                            of the transaction or a decision to prohibit the transaction could prevent you from completing
                                            an initial business combination and require you to liquidate. Disclose the consequences of
                                            liquidation to investors, such as the losses of the investment opportunity in a target company,
                                            any price appreciation in the combined company, and the warrants, which would expire worthless.
                                            Please include an example of your intended disclosure in your response.

Response

The
Company’s sponsor, Murphy Canyon Acquisition Sponsor LLC (the “Sponsor”),
is not a non-U.S. person and does not have substantial ties with a non-U.S. person. The Sponsor is a Delaware limited liability company
and wholly owned subsidiary of Presidio Property Trust, Inc., a publicly traded Maryland corporation whose securities are traded on the
Nasdaq Capital Market (“Presidio”). Each of Presidio’s officers and directors are U.S. citizens who reside in the United
States and to our knowledge, based on ownership filings made with the SEC, no 5% shareholders of Presidio are non-U.S. citizens or corporations.
The Sponsor’s sole officer is Jack Heilbron, its Managing Member. Mr. Heilbron is a U.S. citizen who resides in California.

I
hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions
regarding the information contained herein, please contact our securities counsel Avital Perlman of Sichenzia Ross Ference LLP at (212)
930-9700 or aperlman@srf.law.

    Sincerely,

    /s/
    Adam Sragovicz

    Adam
    Sragovicz, Chief Financial Officer