1. I am Elino M. Ponchinlan, Jr., 28 years old, single, a resident of Banaue, Ifugao.

2. I have a problem regarding my land.

3. It is an agricultural land located at Banao, Banaue, Ifugao covered by a TCT No.
061092 and which I also declared for taxation purposes.
4. My father donated the land to me.
5. Yes. I have a copy of the Deed of Donation with me, the certificate of title and the
tax declaration covering said land.
6. I introduced some improvements, cultivated the land and constructed a small
nipa hut.
7. Yes. I have pictures of the improvements I made over the said land.
8. When I visited it sometime in May 9, 2020, I found out that some of my plants
were destroyed and even my fences were forcibly removed.
9. Upon inquiry, I learned it from my neighbors that it was the doing of Pablo Dela
Cruz. He is my first degree cousin from my father side. I think he is 46 years old
and is also residing at the same barangay.
10. He and his laborers entered my land by force, intimidation, stealth, threats and
strategy and started to build concrete fences.
11. He claims that they own the property and that his father Paquito Dela Cruz is the
real owner of the land.
12. He did not show me anything. I asked him to present any document that would
support his claim but he answered angrily.
13. Yes, I went to his house and confronted him but he just kept on insisting me to
vacate the premises. Otherwise, he would harm me and my family.
14. Yes, I lodged a complaint before the Office of the Punong Barangay on May 12,
2020 but regrettably, all the efforts to amicably settle the dispute were put to vain.
Thus, a Certificate to File an Action was issued and I have it here with me.
15. I don’t know, it’s up to you of what you think would be the other appropriate legal
actions to be instituted. I rely on your competency.
16. Yes, I would want to claim for damages as a result of his wrong doings. Actual
damages for the improvements that have destroyed. Moral damages for the
emotional and mental anguish he caused.
17. I want him to remove at his expense the improvements and structures he already
introduced, vacate the premises peacefully and restore me of my lawful
possession over the subject land.
.