Escolar Documentos
Profissional Documentos
Cultura Documentos
JOHN A. JUAN
Plaintiff, CIVIL CASE NO.___________
JAIME B. TUO
Defendant.
COMPLAINT
1. Plaintiff is of legal age, Filipino Citizen and residing at Casablanca Cagayan where he
may be served with orders, notices and other processes issued by the Honorable Court.
2. Defendant Jaime B. Tuo, is also of legal age, Filipino citizen, is a resident of Bayo,
Iguig Cagayan, where he may be served with summons and other court processes;
3. That Plaintiff is the registered and lawful owner of a parcel of land located at
Casablanca Cagayan covered under Transfer Certificate of Title No. T-12345, and
“… A parcel of land Lot No. 1578 of the Casablanca Public Lands Subdivision, Pls-62,
Cadastral Case No. N-2 LRC Cadastral Redords No. N-16 with the improvements
thereon situated in the Casablanca, Province of Cagayan. Bounded on the NE., points
1-2 by Lot 1577; on the NW., points 2-3, by lot 1576; on the NE., points 3-4, by Road;
and on the SE., points 4-1, by Lot 1579. Containing an area of SEVEN HUNDRED
Attached herewith is a certified true copy of the TCT No. T-12345 and made an integral
5. That because of the fraudulent acts and false pretenses of the defendant, Katibayan ng
Orihinal na Titulo Blg. P-78913 was generated to the prejudice of John Juan
6. That the Title of the defendants have arisen from fraud, false pretenses and
misrepresentation and must necessarily be cancelled and voided and that the title of the
7. That to cite the defendant as an example for good of the public and to forestall other
8. That to aid plaintiffs in the recovery of the property, they have been compelled to
secure the services of counsel whose fees are agreed upon in the amount of
P50,000.00.
PRAYER
WHEREFORE, it is respectfully prayed of this Honorable Court, after due trial that judgment be
rendered ordering:
1. The cancellation of Katibayan ng Orihinal na Titulo Blg. P-78913 in the name of Jaime Tuo
2. That Transfer Certificate of Title No. T-12345 in the name of John Juan to be the lawful and
valid one;
3. The defendant to pay moral damages in the amount of P30,000.00;
4. The defendant to pay exemplary damages in the amount of P30,000.00; and
5. The defendant to pay P50,000.00 as and by way attorney’s fees.
Plaintiffs further pray for such other reliefs which are just and equitable under the premises.
I, JOHN A. JUAN, of legal age, Filipino Citizen and residing at Baculud Iguig, Cagayan after
first having duly sworn to in accordance with law depose and say:
3. The contents therein are true and correct to the best of my personal knowledge
and based on authentic documents.
4. I hereby certify that I have not commenced any action or proceeding involving the
same issue in any tribunal or agency, to the best of my own knowledge, no such
action or proceeding is pending in any other tribunal or agency and should I
thereafter learn that a similar action or proceeding has been filed or is pending in
Court, I will undertake to report such fact within five (5) days therefrom to the
court wherein this Petition and this certification have been filed.
JOHN A. JUAN
Affiant
Branch 31
Plaintiff,
JOHN CHIU CO
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
COMPLAINT
PLAINTIFF, through the undersigned counsel, and unto this Honorable Court most respectfully
submits this Complaint for Forcible Entry and in support hereof makes the following assertions:
1. Plaintiff JUAN AYSION SANTOS, is residing at #123 Narra St., Fairville, Quezon City, where he
may be served with court order and other processes;
2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville, Quezon City where he may
be served with summons, order and other court processes;
3. Plaintiff became owner of a certain parcel of land, through a Deed of Sale from the original
owner, JANICE DY LEE. (A copy of the Deed of Sale is hereto attached as Annex “A”);
4. The parcel of land, situated in #129 Fairville, Barangay Pangsy, Quezon City, is covered by
Transfer of Certificate of Title No. 12345 issued by the Register of Deeds of Quezon City and is
more particularly described, as follows:
(Description)
5. Herein Defendant, through stealth and strategy, occupied the parcel of land in question and
refuses to vacate the same despite repeated oral and written demands. (Copy of the written
demand is hereto attached as Annex “C”);
6. The same acts of the Defendant compelled the Plaintiff to incur damages consisting of
attorney’s fees in the amount of Thirty thousand pesos (P30,000.00) pesos and filing fee, cost
of transportation and other miscellaneous accommodation of its lawyers and other personal
expenses to be incurred in attending the hearings of this case in the amount of FIFTY
THOUSAND PESOS (Php 50,000.00).
PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court that, after
the proceedings, judgment be rendered in favor of the Plaintiff and ordering the Defendant and all
persons claiming rights under him to:
(a) Permanently VACATE the premises in question and give the immediate right of possession to
the Plaintiff;
(b) Pay plaintiff the amount of Thirty Thousand Pesos (P30,000.00) by way of attorney’s fees and
Fifty Thousand Pesos (P50,000.00), by way of other litigation expenses; and,
(c) Pay the cost of this suit.
Plaintiff prays for such other remedies and reliefs as may be deemed just and equitable under the
premises.
Quezon City
Quezon City
Quezon City
Quezon City
I, JUAN AYSION SANTOS, of legal age, after being duly sworn to in accordance with law, depose
and attest:
That I am the petitioner in the above-titled case; that I have caused the preparation of the
foregoing petition and understood the contents thereof, and I hereby declare that all the allegations
contained therein are true and correct according to my knowledge and belief.
Furthermore, I hereby certify that I have not filed nor caused to be filed any other similar case
involving the same issues in the Supreme Court, Court of Appeals or any other tribunal or agency and
that, should there be any other such case/s that may have been filed, I hereby bind myself to inform
the Court of such fact within five (5) days from the discovery thereof.
IN WITNESS WHEREOF, I have hereunto set our hand this 1st day of May 2016, City of Quezon,
Metro Manila, Philippines.
SUBSCRIBED AND SWORN to before me, in the City of Quezon, this 1st day of May 2016, City of
Quezon, Metro Manila, Philippines, affiant having ex habited to me his Drivers License No. F01-
200215674, issued at Quezon City, Philippines.
Notary Public
On January 1, 2015
Book No. 2;
Series 2016.