Republic of the Philippines

REGIONAL TRIAL COURT

9th Judicial Region
Branch ____
Pagadian City

IN RE: PETITION FOR LAND SPECIAL CIVIL CASE NO. _______

VALUATION AND PAYMENT
OF JUST COMPENSATION.

SAMUEL U. BULANG,
Petitioner,

-versus-

CITY GOVERNMENT OF
PAGADIAN, Represented by:
HON. SAMUEL S. CO, in his
Capacity as the Mayor
Of Pagadian City,
Respondent.

X ------------------------------------ /

PETITION

PETITIONER, by counsel, and unto this Honorable Court, most

respectfully avers:

1. That petitioner is of legal age, Filipino citizen, a resident of

F.S. Pajares Avenue, Pagadian City, Philippines, while respondent is
a local government unit, duly existing under Philippines laws, and
with office address at City Hall, Pagadian City, where it may be
served with summons and other processes of this Court;

2. That petitioner is a registered owner of two (2) parcels of

land, to wit:

First Parcel – Lot No. 22-A-6, under Transfer Certificate of Title

No. T-14-030, with an area of 2,570 square
meters, located at Dao, Pagadian City

Second Parcel – Lot No. 21-C-2-A, under Transfer Certificate of

Title No. T-44,193, with an area of 823 square
meters, located at Dao, Pagadian City

Machine copy of the said titles are hereto attached and marked
as Exhibits “A” and “B”, forming an integral part hereof;

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 3. That said parcels of land have been declared for taxation
purpose with assessed value at P116,940.00 and P46,090.00,
respectively, machine copy of Tax Declaration No. 2K9-001193 and
Tax Declaration No. 2K9-001214 are hereto attached and marked as
Exhibits “C” and “D”, respectively, forming an integral part hereof;

4. That sometime in 2017, respondent initiated expropriation

proceedings against herein petitioner before the Regional Trial Court,
Branch 20, Pagadian City, however, it was eventually withdrawn, at
its instant, due to lack of funding, machine copy of the Order, dated 2
July 2020, which dismissed that case is hereto attached and marked
as Exhibit “E”, forming an integral part hereof;

5. That in effect, the said parcels of land belonging to herein

plaintiff were taken by the respondent without paying just
compensation;

6. That this is not in accord with the fundamental law of the

land which states:

"private property shall not be taken for public use

without just compensation." (Section 9, Article 3 of
the 1987 Philippine Constitution)

7. That petitioner has been deprived of his rights over his said
property until now to his great damage and prejudice and even worst,
he could have been paid with that expropriation proceeding had it not
been withdrawn by respondent and until present, no offer whatsoever
was made by the respondent insofar as just payment over the
aforesaid land belonging to herein petitioner;

8. That respondent is duty bound to pay petitioner just

compensation for the value of the property at the time of the filing of
the expropriation complaint which is deemed to be the taking of the
property at P8,000.00 per square meter or in an amount to be
determined by this Court;

9. That the witnesses for the petitioner are, as follows:

a. Samuel U. Bulang – he will substantiate all her

allegations in his petition;

His Judicial Affidavit is hereto attached and marked as

Exhibit “F”;

10. The documentary exhibits for the plaintiff are, as follows:

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 a. Exhibit “A” – Transfer Certificate of Title No. T-14-030, to
prove ownership of petitioner.

b. Exhibit “B” – Transfer Certificate of Title No. T-44,193

c. Exhibit “C” – Tax Declaration No. 2K9-001193, to prove

that the land covered by petitioner’s title has been
declared for taxation purposes.

d. Exhibit “D” – Tax Declaration No. 2K9-001214, to prove

that the land covered by petitioner’s title has been
declared for taxation purposes.

e. Exhibit “E” - RTC Branch 20, Pagadian City, Order, dated

2 July 2020, to prove the withdrawn expropriation
proceedings filed by the respondent.

f. Exhibit “F” – Judicial Affidavit of Petitioner, to

substantiate all the allegations in this petition.

WHEREFORE, PREMISES CONSIDERED, it is respectfully

prayed of this Honorable Court, that after trial, judgment be rendered,
as follows:

1. Fixing the fair market value of the two properties of the

petitioner herein above-described and thereby ordering the
respondent to pay the amount of P8,000.00 per square
meter or as fixed by this Court corresponding just
compensation; and

2. Ordering the respondent to pay the cost of this suit.

Such other reliefs, as are just and equitable under the

premises.
Pagadian City, Philippines, ________________.

ATTY. CRISPER VINCENT T. TINGCANG

Counsel for Petitioner
Roll of Attorney’s No. 72653
IBP No. 279150; 1/9/2023
PTR No. 3750987; 01/03/2023
MCLE Compliance No. VII-0026737
ROA No. 72653
2 Floor Peralta Building 0237 Rizal Avenue
nd

Pagadian City
Email address: perperkobai@yahoo.com