Republic of the Philippines

REGIONAL TRIAL COURT

Branch 2
th
4 Judicial Region
Bulwagan ng Katarungan
Batangas City, Batangas

SPOUSES RAUL GERONIMO and CIVIL CASE NO. 02-76

ANNA GERONIMO, For: Annulment of Deed of
Sale and Damages
Plaintiffs,

-versus-

RICHARD VALDEZ
Defendant
x--------------------------------------------------x

COMPLAINT

COMES NOW the plaintiffs, spouses RAUL GERONIMO and ANNA

GERONIMO, through the undersigned and unto this Honorable Court, most respectfully
states:

1. That the plaintiff ANNA GERONIMO is of legal age, Filipino, married to Raul
Geronimo, and is a resident of 0105 ME Montalbo Road, Bolbok, Batangas City,
where she can be served with summons and other processes of this Honorable
Court;

2. That the plaintiff RAUL GERONIMO, is also of legal age, Filipino and married to
Anna Geronimo and is a resident of 0105 ME Montalbo Road, Bolbok, Batangas
City;

3. That plaintiff ANNA GERONIMO is a certified public accountant of the local

government of Batangas;

4. That plaintiff RAUL GERONIMO is a registered electronics engineer for

Samsung Electronics Batangas;

5. That the defendant, RICHARD VALDEZ, a residence of Batangas City, and

works as a sales manager of Freedom Realty with principal address at 124 Sta.
Clara Heights, Lipa City;

6. That both parties have the capacity to sue and be sued;

7. That since 2006, the plaintiffs ANNA GERONIMO and RAUL GERONIMO had
been living in a one-bedroom condominium located at Ponte Fino Residences,
Batangas City, ;

8. That the said one-bedroom condominium at Ponte Fino Residences has a floor
area of 86 square meters with a purchase value of Three Million Pesos (Php
3,000,000);

9. That the plaintiff RAUL GERONIMO already acquired the condominium in 2001,
prior to his marriage with plaintiff ANNA GERONIMO;

10. That sometime in 2008, the plaintiffs ANNA GERONIMO and RAUL GERONIMO
bought a three-bedroom bungalow at Greenwoods Residences, Batangas City as
the latter are expecting the birth of their first son;

11. That sometime on April 2009, plaintiffs ANNA GERONIMO and RAUL
GERONIMO couple contacted the defendant RAUL GERONIMO, informing that
the said couple are ready to sell their one-bedroom condominium located at
Ponte Fino Residences, Batangas City for Two million Pesos (Php
2,000,000.00);

12. That defendant RAUL GERONIMO agreed to buy the condominium for Two
million Pesos (Php 2,000,000.00), but said that he will be back once the deed of
sale and manager’s check were ready;

13. That no sale was consummated since sometime on May 2009, plaintiff ANNA
GERONIMO left for the United States to give birth;

14. That while in the United States, plaintiff ANNA GERONIMO decided not to sell
the one-bedroom condominium anymore;

15. That defendant RAUL GERONIMO, with knowledge that plaintiff ANNA
GERONIMO was abroad, willfully and flagrantly created a deed of sale without
plaintiff ANNA GERONIMO as one of the signatories;

16. That sometime on June 2009, plaintiff ANNA GERONIMO was informed that
plaintiff RAUL GERONIMO signed a deed of sale for the condominium unit,
without the former’s consent;

17. That after giving birth, on September 2009, plaintiff ANNA GERONIMO arrived in
the Philippines;

18. That the plaintiff ANNA GERONIMO immediately contacted defendant RICHARD
VALDEZ informing that the former was not selling the condominium unit and
offered to return the payment of two million pesos (Php 2,000,000.00);

19. That defendant RAUL GERONIMO insisted that the sale had been
consummated and refused to accept the money, even the sale was without the
consent of plaintiff ANNA GERONIMO.
20. That as a result of defendant RAUL GERONIMO’s willful and flagrant disregards
for their clients, herein plaintiff ANNA GERONIMO suffered sleepless nights,
anxiety that the condominium unit which were home for the couples for more
than ten years and which will be given to their first son will be lost, prompting her
to be hospitalized for two days and required bed rest for seven more days;

21. That the willful, flagrant and malicious disregard of the defendant has worked as
an injustice to the rights of the plaintiffs;

22. That as a consequence, plaintiffs were compelled to institute the instant action
against the defendant. They were constrained to retain the services of counsel to
whom they paid an acceptance fee of Thirty Thousand Pesos (Php30,000.00)
and bound themselves to pay the undersigned counsel an appearance fee of
One Thousand Pesos (Php1,000.00) per appearance.

PRAYER

WHEREFORE, the forgoing premises considered, it is most respectfully

prayed that this Honorable Court render judgment ordering Defendant to pay
herein Plaintiff the following amounts:

1. Php105,925.00, representing the actual damages suffered by the

plaintiffs;

2. Php20,000.00 as exemplary damages

3. Php40,000.00 as attorney’s fee;

Plaintiffs likewise pray for such other reliefs as are just and equitable
under the premises.

SO PRAYED.

Batangas City.

October 08, 2021

CRISZUS NINO V. IBON

Cousel for the Plaintiffs
PTR No. 1234567/01-06-15/Batangas City
IBP No. 123456/11-06-10/BatangasCity
Roll No. 123456
MCLE No. 123456, Series of 2014,
dated March 5, 2014
136 Scarlet Mansion, Lipa City, Batangas