Republic of the Philippines

REGIONAL TRIAL COURT

Branch 22
Davao City

BASTIEN SALABANZI,
Plaintiff,
-versus- Civil Case No. 111-662-888
For: Complaint for Foreclosure of
Real Estate Mortgage
TOMAS SALABANZI,
Defendant.
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COMPLAINT FOR JUDICIAL PARTITION OF REAL ESTATE

COMES NOW the plaintiff by the undersigned attorney, and unto this
Honorable Court, respectfully avers:

1. That the plaintiff and the defendant are both of age, and residents of
55 Act St.,Ecoland Subd., Davao City, Davao del Sur, Philippines;

2. That the said parties are co-owners, by virtue of intestate inheritance

from their deceased parents, of certain real properties, more particularly
described as follows, to wit:

a.) Cadastral Lot No. 784-Part, Cad-457-D --- A parcel of land

situated in Parokya ni Edgar, Brgy. Tibalog, Davao City, bounded on
the North 03 (Lot No.788), on the South 07 (Lot No.787-Part), on the
East 05 (Lot No.789-Part), and on the West 02 (Lot No.783) x x x
containing an area of FIVE THOUSAND (5,000.00) SQUARE
METERS, more or less x x x”;

b.) Lot No. 656 --- A parcel of land situated in Purok Dragon,
Brgy. Calinan, Davao City, Philippines, bounded on the North by
Davao River, on the South 08 (Lot No.655), on the East 03, 04, 07 (Lot
No.652, 654 and 663-Part), and on the West by dry creek and calejon x
x x containing an area of TWO AND POINT FIVE (2.5) HECTARES,
more or less;
 3. That the plaintiff desires that the above real estate be partitioned
between the plaintiff and the defendant;

4. That the plaintiff has requested of the defendant that the above-
described real estate be amicably partitioned between them by mutual
agreement, but the said defendant refused and continues to refuse to do so.

WHEREFORE, it is respectfully prayed:

(a) That, after due hearing, the partition of the above-described real
estate be ordered between the plaintiff and the defendant, share and
share alike;

(b) That the costs and expenses of these proceedings be taxed solely
against the defendant.

City of Davao, Philippines this February 6, 2020.

ATTY. PAULO JOSE S. VILLARIN

Counsel of the Plaintiff
Roll of Attorneys No. 696969
PTR No. 69669, 4-24-20, Davao City
IBP No. 69669, 4-24-20, Davao City
MCLE Compliance No. VII-0220293; 4-19-19
Valid until April 14, 2022
Ecoland, Davao City
REPUBLIC OF THE PHILIPPINES)
CITY OF DAVAO ) S.S.
x----------------------------------------------x

VERIFICATION AND CERTIFICATION

I, BASTIAN SALABANZI, of legal age, after having been duly sworn in

accordance with law, depose and state that:

1. I am a petitioner in the above-stated case;

2. I caused the preparation of the foregoing petition;
3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of documents
and records in my possession;
4. I have not commenced any other action or proceeding involving the same
issues in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;
5. To the best of my knowledge and belief, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;
6. If I should thereafter learn that a similar action or proceeding has been filed
or is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this Honorable Court.

SUBSCRIBED AND SWORN to before me this 6tth day of January

2020 at Davao City, affiant exhibiting to me his Driver’s License with License
No. 555-333-111, issued by the Land Transportation Office of Davao City,
Philippines.

Doc. No.__;
Page No.__;
Book No.__;
Series of 2020.