Republic of the Philippines

REGIONAL TRIAL COURT

8th Judicial Region
Branch 11
Bulwagan Ng Katarungan, Magsaysay Blvd.,
Tacloban City, Leyte

KATY PERRY,

Plaintiff

CIVIL CASE NO: A-12-34567

FOR: QUIETING OF TITLE, TCT No.: 123-
4567891011
-versus-

MANDY MOORE
Defendant
x - - - - - - - - - - - - - - - - - - --- x

VERIFIED COMPLAINT

COMES NOW, the Plaintiff, through the undersigned counsel and unto
this Honorable Court, is respectfully and humbly filing this “Verified Complaint”
and avers that:

THE PARTIES:

1. The Plaintiff – Katy Perry, of legal age, Filipino, married, has the
capacity to sue and be sued, and may be served with summons and other court
processes in his residence address at Del Pilar St., Tacloban City, Leyte,

2. On March 20, 2020, plaintif entered into a contract with

Camella
Homes for the purchase in installments of a lot located at Blk 5, Lot 40,
Regina Hills, Nula Tula, Tacloban City covered by TCT No. 123-
4567891011 of the Registry of Deeds for Tacloban City.
 3. That immediately thereafter, plaintif took possession of the
property covered by TCT No. 123-4567891011 of the Registry of Deeds for
Tacloban City and constructed a residential house for her family. Hence,
from March of 2020 up to the present date, plaintif was in continuous and
notorious possession of the property covered by 123-4567891011 of the
Registry of Deeds for Tacloban City to the exclusion of others and in the
concept of an owner;

4. In August of 2020, plaintiff was able to fully pay for the agreed
purchase price of the lot covered by TCT No. 123-4567891011 of the
Registry of Deeds for Tacloban City and accordingly, a Deed of Absolute
Sale dated August 4, 2020 was executed by plaintiff and Camella Homes
and the original owner’s copy of TCT No. 123-4567891011 of the Registry
of Deeds for Tacloban City, accordingly turned over to them;

5. That sometime December 2020, plaintiff was surprised to learn

from the Registry of Deeds for Tacloban City that on October 9, 2020, the
subject lot was sold by Camella Homes to the defendant, Mandy Moore, for
the price and consideration of P1.9M as shown in Moore’s Final Deed of
Sale

6. The levy on attachment and the execution sale undertaken by

Mandy Moore is clearly illegal there being no notice given by said individual
to the occupants of the property in question;

PRAYER

WHEREFORE, PREMISES CONSIDERED it is most respectfully and

humbly prayed:

(a)That the property in question be ordered delivered to the

plaintiff;

(b)That defendant be made to pay the costs of this suit;

(c) And that plaintiff be granted such futher relief consistent with
law and equity.
 Other reliefs that may be just and equitable under the premises are
likewise prayed for.

RESPECTFULLY SUBMITTED.

Tacloban City, Leyte, this 20th day December of 2020.

VERIFICATION AND CERTIFICATION

REPUBLIC OF THE PHILIPPINES )

CITY OF TACLOBAN ) S.S.

I, Katy Perry, Filipino, of legal age residing at Del Pilar St., Tacloban
City, Leyte,, after being sworn to in accordance with law, deposes and says
that:

1. I am the Plaintiff in the above-entitled case;

2. The facts stated in the above complaint are true and correct to the
best of our knowledge and authentic records;

3. I have not commenced any action or filed any claim involving the
same issues in any court, tribunal or quasi-judicial agency and, to
the best of my knowledge, no such other action or claim is pendig
in them; and

4. If I should learn that the same or similar action or claim has been
filed or is pending after its filing, I shall report that fact within five
(5) days from notice the court or where the complaint or initiatory
pleading has been filed.
 Affiant
Katy Perry

SUBSCRIBED AND SWORN to before me, this 20 th day of

December, 2020 in the City of Tacloban, affiant exhibiting to me his Driver’s
License HO1-12-345678, issued at Tacloban City on January 5, 2017.