REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Davao
Branch 1

ADA WONG
Plaintiff,

-versus- CIVIL CASE No. 22222

For: FORCIBLE ENTRY (EJECTMENT)

LEON KENNEDY
Defendant.
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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 , is residing at 4 Agdao, Davao City, where he may be served with

court order and other processes;

2. Defendant is a resident of 12 Matina, Davao 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, CLAIRE. (A copy of the Deed of Sale is hereto
attached as Annex “A”);

4. The parcel of land, situated in 69 Matina, Davao City, is covered by Transfer

of Certificate of Title No. 12345 issued by the Register of Deeds of Davao
City and is more particularly described, as follows:

TCT No. T-12345

“A parcel of land of the subdivision project situated in

the Barangay of Matina Aplaya; City of Davao; Island of
Mindanao.

Bounded as follows: On the N., along line 2-3 by Road

Lot 30/6.50 m. wide); on the E., along line 3-4 by lot 8;
on the S. along line 4-1, by lot 9; on the W., along line 1-
 2 by lot 12, all of block 33, all of the subdivision plan.
Beginning at a point marked: “1” on plan, being N. 19
deg. 44’W., 492.85 m. from M.B.M. No. 17 Cad. 102.
Containing an area of TWO HUNDRED FIFTY (100)
SQUARE METERS, more or less.”

(Copy of TCT- 12345 is hereto attached as ANNEX “B”);

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).

7. This action is governed by the Rules on Summary Procedure;

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.

January 30, 2020. Davao City, Philippines.

ATTY. EMILIO SORIANO

 Counsel for Plaintiff

VERIFICATION AND CERTIFICATION

AGAINST NON- FORUM SHOPPING

I, ADA WONG, 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 30 th day of

January 2020, City of Davao, Philippines.

ADA WONG
Affiant
CTC No. 1234565
Issued On: May 4, 2018
Issued At: Davao City
 SUBSCRIBED AND SWORN to before me, in the City of Davao, this 30 th
day of January 2020, City of Davao, Metro Manila, Philippines, affiant having
exhibited to me her Driver’s License No. 612358, issued at Davao City,
Philippines.

Doc. No. _____; EMILIO O. SORIANO

Page No. _____; NOTARY PUBLIC
Book No. _____; Until Dec. 31, 2022
Series of 2019. Serial No. 2021-999-9999
PTR. No. 99999/01-08-21
Roll of Atty.’s No. 99999
Commission Serial No. 2019-080-2022
IBP. Lifetime Roll No. 99999