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Plaintiffs
-versus- FOR: NULLIFICATION OF DEED OF
DONATION, CANCELLATION OF
CERTIFICATE OF TITLE,
RECONVEYANCE, DAMAGES AND
ATTORNEY’S FEES
MUNICIPALITY OF STO.TOMAS,
Represented by DANIEL
BATOSALEM JR. as incumbent
Mayor, THE REGISTER OF DEEDS
OF THE PROVINCE OF DAVAO DEL
NORTE,
Defendants
X- - - - - - - - - - - - - - -X
COMPLAINT
COMES NOW, Plaintiffs, by the undersigned counsels, unto the
Honorable Regional Trial Court, most respectfully submit this
Complaint and aver:
PREFATORY STATEMENT
(synopsis of the case)
Out of love and generosity, the late Spouses Damian and Marcosa Blase, who are both
unlettered, executed several deeds of donation to donate a vast portion of their land to the
Municipality of Sto.Tomas… However, it was belatedly found out that a portion of the Spouses
Blase’s land, of which they have no absolute intention of donating since they wish and intend the
same to be their children’s inheritance, was mistakenly donated to the Municipality… now, the
herein plaintiffs hereby most respectfully pray for the just reconveyance of the said land, and for
such other speedy and equitable reliefs before this Honorable Court...
A attached herewith is a copy of the SPECIAL POWER OF ATTORNEY and made an integral part hereof and marked as ANNEX “A”
B attached herewith is a copy of the 7 SEPTEMBER 1962 DEED OF DONATION and made an integral part hereof and marked as ANNEX “B”
C
attached herewith is a copy of the 2 AUGUST 1972 DEED OF DONATION (ROAD LOT 2) and made an integral part hereof and marked as ANNEX “C”
D
attached herewith is a copy of the 2 AUGUST 1972 DEED OF DONATION (MARKET PLACE) and made an integral part hereof and marked as ANNEX “D”
E
attached herewith is a copy of the 2 AUGUST 1972 DEED OF DONATION (ROAD LOT 1) and made an integral part hereof and marked as ANNEX “E”
F
attached herewith is a copy of the CERTIFIED TRUE COPY TCT NO. T-12115 and made an integral part hereof and marked as ANNEX “F”
G
attached herewith is a copy of the RECTO’S AFFIDAVIT and made an integral part hereof and marked as ANNEX “G”
H
attached herewith is a copy of the RESOLUTION NO. 89-141 and made an integral part hereof and marked as ANNEX “H”
I
attached herewith is a copy of the MPDC CERTIFICATION and made an integral part hereof and marked as ANNEX “I”
J
attached herewith is a copy of the RESOLUTION NO. 38 SERIES OF 1996 and made an integral part hereof and marked as ANNEX “J”
K
attached herewith is a copy of the COMMITTEE REPORT NO. 127 SERIES OF 2017 and made an integral part hereof and marked as ANNEX “K”
L
attached herewith is a copy of the COMMITTEE REPORT NO. 154 SERIES OF 2017 and made an integral part hereof and marked as ANNEX “L”
prayers
(legal and equitable reliefs prayed for)
Respectfully Submitted.
ORLANDO INCLINO
Assisted by:
ORLANDO INCLINO
Affiant
CEI: __________________________
ATTY. JONATHAN P. UY
Notary Public
Until December 31, 2018
Doc. No.___; PTR No. 2250769; January 8, 2018
Page No.___; IBP OR # 006403; May 21, 2017
Book No.___; Roll No. 67339
Series of 2018 TIN No. 452-694-284
Represented by: Assisted by: ATTY. JONATHAN
P. UY
ORLANDO INCLINO
ATTY. JONATHAN P. UY
Counsel for the Plaintiff
Second Floor, Pereyras Building,
Pioneer Avenue, Tagum City, DDN
MCLE COMPLIANCE Exempt for
recently passing the 2016 Bar Exam
PTR No. 881758
IBP OR # 0989174
Roll No. 67339
TIN 452-694-284
Copy furnished:
Department of Justice
Padre Faura Street
Ermita, Manila 1000
ROWENA M. QUIAMCO
Respondent-Appellee
Quirante II Street
Tagum City, Davao del Norte
VERIFICATION AND CERTIFICATION OF
NON-FORUM SHOPPING
I, ORLANDO INCLINO, of legal age, married, Filipino,
after being duly sworn to in accordance with law, do hereby
depose and say that:
ORLANDO INCLINO
Affiant
CEI:
SUBSCRIBED AND SWORN TO before me this _____________,
affiant exhibiting her competent evidence of identity.
ATTY. JONATHAN P. UY
Notary Public
Until December 31, 2018
Doc. No.___; PTR No. 2250769; January 8, 2018
Page No.___; IBP OR # 006403; May 21, 2017
Book No.___; Roll No. 67339
Series of 2018 TIN No. 452-694-284
AFFIDAVIT OF COMPLETENESS
(DECLARATION OF COMPLETENESS)