IV

SECOND CAUSE OF ACTION

(Payment of Moral Damages)

1) The foregoing paragraphs are repleaded herein by way of

reference.

2) Defendants' wanton, fraudulent, reckless, oppressive and

malevolent acts and omissions, particularly in illegally, unlawfully
and fraudulent registration of the subject property under the names
of Benjamin Bautista and Jaime Sargote, has caused the Plaintiff
to experience mental anguish, moral shock and sleepless nights.

3) Consequently, Defendants should be ordered to pay Plaintiff the

amount of ____________________________ as and for moral
damages or in such amount as the Honorable Court may find just
and reasonable.

V
THIRD CAUSE OF ACTION
(Payment of Exemplary Damages)

4) The foregoing paragraphs are repleaded herein by way of

reference.

5) By fraudulently registering the subject property in the name of

Benjamin Bautista and Jaime Sargote, Defendants acted in a
wanton, fraudulent, reckless, oppressive, or malevolent manner.

6) Consequently, by way of example or correction for the public good,

Defendants should be ordered to pay Plainitff at least
____________________________ as exemplary damages.

VI
FOURTH CAUSE OF ACTION
(Payment of Attorney's Fees and Litigation Expenses)

7) The foregoing paragraphs are repleaded herein by way of

reference.

8) To protect his rights and interests and to seek redress for his
grievance against Defendants, Plaintiff was compelled to engage
the services of counsel for a fee and incur expenses for litigation.
 9) Thus, Defendants should be ordered to pay the Plaintiff attorney’s
fees in the amount of ____________________________ as
acceptance fees, ____________________________ per hearing as
appearance fees and ____________________________ per
pleading.

PRAYER

WHEREFORE, premises considered, Plaintiff most respectfully prays

that a Judgment be issued in his favor and against the Defendants as
follows:

a. Under the first Cause of Action, declaring Plaintiff as the true,

absolute and lawful owner of the subject property and ordering
Defendant to reconvey to him the Subject Property.

b. Ordering the Registry of Deeds of lsabela to cancel the title under

the name of the Defendants and directing it to issue a new one
under the name of the Plaintiff, as a consequence of the
reconveyance.

c. Under the Second Cause of action, ordering Defendants to pay

____________________________ as and for moral damages;

d. Under the Third Cause of Action, ordering Defendants to pay

____________________________ as exemplary damages;

e. Under the Fourth Cause of Action, ordering Defendants to pay the

amount of ____________________________as acceptance fees,
____________________________ per hearing as appearance fees
and ____________________________ per pleading, motion and
judicial affidavit.

Other just and equitable reliefs undet the circumstances arc also prayed
for.

Santiago City, Isabela. ______________ 2019