Sample Forcible Entry Ejectment

JUDICIAL FORMS (SUMMARY PROCEEDINGS)
EJECTMENT (FORCIBLE ENTRY)

COMPLAINT
Republic of the Philippines
NATIONAL CAPITAL JUDICIAL REGION
METROPOLITAN TRIAL COURT
QUEZON CITY
Branch 031
JUAN AYSION SANTOS
Plaintiff,
-versus-
CIVIL CASE No. Q-12345

For: EJECTMENT (FORCIBLE ENTRY)
JOHN CHIU CO
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
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 JUAN AYSION SANTOS, is residing at #123 Narra St.,
Fairville, Quezon City, where he may be served with court order and other
processes;
2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville,
Quezon 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, JANICE DY LEE. (A copy of the Deed of Sale
is hereto attached as Annex A);
4. The parcel of land, situated in #129 Fairville, Barangay Pangsy, Quezon
City, is covered by Transfer of Certificate of Title No. 12345 issued by the
Register of Deeds od Quezon City and is more particularly described, as
follows:
(Description)
(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 attorneys fees in the amount of Thirty thousand pesos
(P30,000.00) pesos and filing fee, cost of transportation and other
1

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 25,000.00).
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 attorneys fees and Twenty Five Thousand Pesos (P25,000.00), 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.
May 1, 2011. Quezon City, Metro Manila.
ATTY. PHOEMELA G. CRUZ

Counsel for Plaintiff
Quezon City
Roll of Attorneys No. 1234567
IBP No. A-1234567
PTR No. A- 1234567
MCLE No. A-1234567
VERIFICATION AND CERTIFICATION

AGAINST NON- FORUM SHOPPING
I, JUAN AYSION SANTOS, 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 1 st day of
May 2012, City of Quezon, Metro Manila, Philippines.
JUAN AYSION SANTOS

Affiant
CTC No. 1234565
Issued On: May 4, 2011
Issued At: Quezon City
SUBSCRIBED AND SWORN to before me, in the City of Quezon, this
1st day of May 2012, City of Quezon, Metro Manila, Philippines, affiant having ex
habited to me his Drivers License No. ___________, issued at Quezon City,
Philippines.
ATTY. DAN B. SAN

Notary Public
Until December 31, 2013
PTR No. A-123056
Issued at Quezon City
On January 1, 2012
Doc. No. 1;
Page No. 1;
Book No. 1;
Series 2012.

ANSWER
QUEZON CITY
Branch 031
JUAN AYSION SANTOS,
Plaintiff,
-versus-

JOHN CHIU CO
Defendant.
x- - - - - - - - - - - - - - - - - - - - - - - - x
ANSWER
COMES NOW THE DEFENDANT JOHN CHIU CO, through the
undersigned counsel, and unto this Honorable Court most respectfully submits
that:
1
DEFENDANT ADMITS the allegations in paragraph 1 and

paragraph 2 of complaint insofar as they relate to their personal
circumstances;
2 DEFENDANT specifically DENIES the allegations in paragraph 5

since he was given authority by JANICE DY LEE to occupy the
land.
PRAYER
WHEREFORE, the answering defendant, most respectfully pray
for judgment:
1
Dismissing the complaint with costs against the plaintiff; and
2 The Defendants further pray for any and all relief and remedies
fitting and proper under the premises.

City of Quezon, June 01, 2012
ATTY. SHU B. SAY

Counsel for Defendant
Quezon City
Roll of Attorneys No. A-123467
IBP No.A-123456
PTR No. A-1234557
MCLE No. A123457
VERIFICATION
I, JOHN CHIU CO, Filipino, of legal age, and residing at 123 Acacia St.,
Fairville, Quezon City, Metro Manila after having been duly sworn in accordance
with law, hereby depose and state that I, the defendant in the present case;
caused the preparation of the foregoing Answer; that I have read and understood
the contents thereof and that the same are true and correct as to the best of our
knowledge and belief.
City of Quezon, June 01, 2012
JOHN CHIU CO
Defendant
CTC No. B-124843
On March 3, 2012
Copy furnished:
Quezon City

REPLY
QUEZON CITY
Branch 031
JUAN AYSION SANTOS,
Plaintiff,
-versus-

JOHN CHIU CO,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
REPLY
COMES NOW Plaintiff through the undersigned counsel and hereby
respectfully states that:
1. In the Defendants Answer, the said defendant stated that plaintiff allowed
him to use the premises of the lot;
2. Defendant is evidently misleading the court in denying the existence of the
cause of action;
PRAYER
WHEREFORE, Plaintiff respectfully prays that judgment be rendered in his
favor in accordance with the original prayer set forth in the plaintiffs complaint.
Quezon City. May 4, 2012

Quezon City
6

IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567

POSITION PAPER
QUEZON CITY
Branch 031
JUAN AYSION SANTOS,
Plaintiff,
-versus-

JOHN CHIU CO,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
POSITION PAPER FOR THE PLAINTIFF
PLAINTIFF, by counsel, unto this Honorable Office, respectfully submits
this Position Paper in the above entitled case, and alleges that:
THE CASE
The case arose from the stealthy strategic usurpation of the defendant of
the property of the herein plaintiff. Plaintiff now prays for the ejectment of the
defendant and the payment of damages.
FACTS OF THE CASE
1. Plaintiff JUAN AYSION SANTOS, is a resident of #123 Narra St., Fairville,
Quezon City, where they may be served with court order and other
processes;
Quezon City where he may be serve with summons, order and other court
processes;
3. Plaintiff became owners of a certain parcel of land, through a Deed of Sale
from the original owner, JANICE DY LEE.
7
4. The parcel of land is situated in 129 Fairville, Barangay Pangsy, City of

Quezon, Metro Manila covered by TCT No. 12345.
5. That herein Defendant, through stealth and strategy, occupied the parcel
of land in question.
6. That Defendant, despite repeated demand, refused to vacate the land.
7. The same acts of the Defendant compelled the Plaintiff to incur litigation
expenses consisting of attorneys fees in the amount of THIRTY
THOUSAND (Php 30,000.00) and other litigation expenses consisting of
filing fees, cost of transportation and other miscellaneous expenses to be
incurred in attending the hearings of this case at TWENTY FIVE
THOUSAND PESOS (Php 25,000.00).
ISSUE
1. Whether or not defendant should be ejected.
2. Whether or not plaintiff is entitled to damages.
ARGUMENTS
1. Under the Rules of Court, where a person unlawfully deprives another of
his property, an ejectment for forcible entry case may be filed against the
usurper
2. Under the Civil Code, the plaintiff is entitled to moral and actual damages.
RESERVATIONS
Plaintiff respectfully reserves its right to file supplemental pleadings or
adduce additional evidence in due course of the proceedings whenever necessary
and proper.
PRAYER
WHEREFORE, plaintiff prays that the reliefs prayed for in the instant
complaint be granted.

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567

POSITION PAPER
QUEZON CITY
Branch 031
JUAN AYSION SANTOS,
Plaintiff,
-versus-

JOHN CHIU CO,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
POSITION PAPER FOR THE DEFENDANT
DEFENDANT, by counsel, unto this Honorable Office, respectfully
submits this Position Paper in the above-titled case, and alleges that:
THE CASE
The is an action for Forcible Entry commenced by the Plaintiff JUAN
AYSION SANTOS against the defendant JOHN CHIU CO. The subject matter
of this action is a piece of land identified as in #129 Fairville, Barangay Pangsy,
City of Quezon, Metro Manila. Copy of TCT- 12345 Lot No. 2-A-1 situated at
Barangay Pangsy, City of Quezon under OCT No.123456 issued in the name of the
late JUANA DELA CRUZ -SANTOS registered in the Registry of Deeds of Quezon
City.
FACTS OF THE CASE
1. Plaintiff JUAN AYSION SANTOS, with residence and postal address at
#123 Narra St., Fairville, Quezon City, where they may be served with
court order and other processes;
processes;

3. Plaintiff became owner of a certain parcel of land, through a Deed of Sale
from the original owner, JANICE DY LEE Copy of the Deed of Sale is
hereto attached as Annex A;
4. The parcel of land is situated in #129 Fairville, Barangay Pangsy, City of
Quezon, Metro Manila. Copy of TCT- 12345 is hereto attached as ANNEX
B;
5. That as early 2002, JOHN CHIU CO took possession of the property under
Lot No. 2-A-1 and constructed a nipa hut thereon.
6. On April 15, 2012 the defendants were surprised that plaintiff JUAN
AYSION SANTOS approached and informed him that he was the lawful
owner of the land and they acquired it through a sale because their mother
never sold the said property when she was alive.
7. On May 19, 2012 the defendant received a summon from the Metropolitan
Trial Court to answer for a complaint filed against them for forcible entry.
On June 1, 2012 the defendant thru the undersigned counsel filed an
answer to the complaint.
8. The same acts of the Plaintiff compelled the Defendant to incur litigation
expenses consisting of filing fee, cost of transportation and other
to be incurred in attending the hearings of this case, etc., fixed at FIFTY
THOUSAND PESOS (Php 50,000.00), which the Plaintiff should also be
held answerable therefore;
ISSUE
1. Whether the defendants can be ejected by forcible entry under Rule 70
Section 1 of the Revised the Rules of Court.
ARGUMENTS
1. The defendants cannot be ejected on the subject land for the reason that
for forcible entry to attach the following circumstance must concur:
(a)That the person is deprived of his property;
(b)That such deprivation is due to force, intimidation, threat, strategy or
stealth; and
(c)That such person has real title over such property.
In this case, the Defendant made no deprivation of possession on the
Plaintiff because the property was already in his possession and the
plaintiff started to claim such land on April 2012 based on the alleged sale
of JANICE DY LEE to the Plaintiff. This would only show that
defendant was in a threat of losing the subject land which they lawfully
acquired through the permission of JANICE DY LEE.
Moreover the plaintiff has never been in possession of such land from the
time it was acquired by the defendants. This means that plaintiff was never
in possession of the property as one of the elements of forcible entry.
10
RESERVATIONS
and proper.
PRAYER
WHEREFORE, defendant prays that the reliefs he prayed for in his
complaint be granted and any other reliefs which the court may award to the
plaintiff which is just and equitable under the circumstances.
ATTY. SHU B. SAY

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567
11

ARBITRATION / COMPROMISE AGREEMENT
QUEZON CITY
Branch 031
JUAN AYSION SANTOS,
Plaintiff,
-versus-

JOHN CHIU CO ,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
COMPROMISE AGREEMENT
THE UNDERSIGNED PARTIES
JUAN AYSION SANTOS,
resident of #123 Narra St., Fairville, Quezon City
AND
JOHN CHIU CO,
resident of #123 Acacia St., Fairville, Quezon City
AGREE as follows:
1. That JOHN CHIU CO shall pay for the rent on the property including
back rentals;
2. The plaintiff shall drop this civil case against the defendant.
IN WITNESS WHEREOF, the Parties hereto have mutually and voluntarily
agreed to the above stipulations, and sign this Agreement, at the
METROPOLITAN TRIAL COURT of Quezon City, Branch 031, on this 15 th day of
July, 2012 for the consideration and approval of the Honorable Court.
JUAN AYSION SANTOS

Plaintiff
JOHN CHIU CO
Defendant
12
Assisted by:
JUSTIN C. BERN
Mediator
JESICA A. ASE
Mediation-Supervisor/Coordinator
E J E C T M E N T (UNLAWFUL DETAINER)
COMPLAINT
QUEZON CITY
Branch 031
JUAN AYSION SANTOS
Plaintiff,
-versus-
CIVIL CASE No. H-12346

For: EJECTMENT (UNLAWFUL DETAINER)
JOHN CHIU CO
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
COMPLAINT
PLAINTIFF, through the undersigned counsel, and unto this Honorable
Court most respectfully submit this Complaint for Unlawful Detainer and in
support hereof makes the following assertion:
1. Plaintiff JUAN AYSION SANTOSs residence and postal address is at #123
Narra St., Fairville, Quezon City, where they may be served with court
order and other processes;
2. Defendant JOHN CHIU CO residence and postal address is at #123 Acacia
St., Fairville, Quezon City where he may be served with summons, order
and other court processes;
3. Initially, the possession of property located at 129 Fairkes St., Fairville,
Quezon City by the defendant was by a contract of lease with or by
tolerance of the plaintiff;
4. That defendants lease expired 2 months ago;
5. That defendant refused to turn over the said property even after demand
to do so is made thus, such possession became illegal;
6. Thereafter, the defendant remained in possession of the property and
deprived the plaintiff of the enjoyment thereof; and
13

THOUSAND PESOS (Php 50,000.00), which the Defendant should also
be held answerable;
8. This action is governed by the Rules on Summary Procedure.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed unto this
Honorable Court that:
(a) After trial, judgment be rendered in favor of herein Plaintiff and ordering
Defendant and all persons claiming right under him to permanently
VACATE the premises in question and give the immediate possession
thereof to the Plaintiff;
(b) Pay plaintiff the amount of FIFTY THOUSAND PESOS (Php50,000.00),
as and by way of attorneys fees;
(c) Pay plaintiff the cost of this suit.
Plaintiff prays for such other remedies and reliefs as may be deemed just and
equitable under the premises.
May 10, 2012. Quezon City.
Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567

I, JUAN AYSION SANTOS, of legal age, after being duly sworn to in
accordance with law, depose and says:
That I am the petitioner in the above-titled case; that I have caused the
preparation of 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 a
similar case involving the same issues in the Supreme Court, Court of Appeals or
any tribunal or agency, I shall inform the Court, tribunal or agency of such fact
within five (5) days thereof.
14

IN WITNESS WHEREOF, we have hereunto set our hand this 10 th day
of May 2012, City of Quezon, Metro Manila, Philippines.
JUAN AYSION SANTOS

Plaintiff
CTC No. 1234565
Issued On: March 4, 2012
Issued At: Quezon City
E J E C T M E N T ( UNLAWFUL DETAINER)
ANSWER
QUEZON CITY
Branch 031
JUAN AYSION SANTOS
Plaintiff,
-versus-

JOHN CHIU CO
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
ANSWER
DEFENDANT, through the undersigned counsel, and unto this Honorable
Court most respectfully submit this ANSWER for Unlawful Detainer and in
support hereof makes the following assertion:
1. Defendant admits paragraphs 1 and 2 insofar as the personal
circumstances of the plaintiff and defendant are concerned;
2. Defendant specifically denies paragraph 3 of the complaint in as much as
the plaintiff allowed for the extension of the lease contract;
3. Defendant partially admits paragraph 4 and 5 in as much as he refuses to
turn over the said property only because of the extension granted to him
by the plaintiff;
THOUSAND PESOS (Php 50,000.00), which the Plaintiff should also be
held answerable therefore;
15

5. This action is governed by the Rules on Summary Procedure;
PRAYER
WHEREFORE, premises considered, it is respectfully prayed unto this
Honorable Court that:
(d) After trial, judgment be rendered in favor of herein Defendant dismissing
the complaint;
(e) Pay the Defendant the amount of FIFTY THOUSAND PESOS
(Php50,000.00), as and by way of attorneys fees;
(f) Pay the Defendant the cost of this suit.
Defendant prays for such other remedies and reliefs as may be deemed just
and equitable under the premises.
May 16, 2012. Quezon City.
ATTY. SHU B. SAY

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567

I, JOHN CHIU CO, of legal age, after being duly sworn to in accordance
with law, depose and says:
That I am the Defendant in the above-entitled case; that I have caused the
preparation of the foregoing Answer 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 a
similar case involving the same issues in the Supreme Court, Court of Appeals or
any tribunal or agency, I shall inform the Court, tribunal or agency of such fact
within five (5) days thereof.
IN WITNESS WHEREOF, we have hereunto set our hand this 16 th day
of May 2012, City of Quezon, Metro Manila, Philippines.
JOHN CHIU CO
Defendant
CTC No. B-124843
16

On March 3, 2012
REPLY
QUEZON CITY
Branch 031
JUAN AYSION SANTOS,
Plaintiff,
-versus-

JOHN CHIU CO,
Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
REPLY
COMES NOW Plaintiff through the undersigned counsel and hereby
respectfully states that:
1. In the Defendants Answer, the said defendant stated that plaintiff allowed
him to extend the lease of the property in question;
2. Defendant is evidently misleading the court in alleging the claim in as much
as the plaintiff did not extend such lease. Neither is there any evidence of
such extension;
PRAYER
WHEREFORE, Plaintiff respectfully prays that judgment be rendered in his
favor in accordance with the original prayer set forth in the plaintiffs complaint.

17

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567
POSITION PAPER
QUEZON CITY
Branch 031
JUAN AYSION SANTOS,
Plaintiff,
-versus-

JOHN CHIU CO,

Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
POSITION PAPER FOR THE PLAINTIFF
this Position Paper in the above entitled case, and alleged that:
THE CASE
The case arose from the expiration of the lease agreement between the
plaintiff and defendant and the latters subsequent refusal to vacate the formers
property. Plaintiff now prays for the ejectment of the defendant and the payment
of damages.
FACTS OF THE CASE
#123 Narra St., Fairville, Quezon City, where they may be serve with court
order and other processes;
processes;
18

3. Defendant was a lessee of the plaintitffs property in 129 Fairkes St.,
Fairville, Quezon City;
4. That defendants lease expired 2 months ago
5. That defendant refuses to turn over the said property even after demand
is made;
be held answerable therefore;
ISSUE
3. Whether defendant should be ejected.
4. Whether plaintiff is entitled to damages.
ARGUMENTS
1. Under the law, where a person unlawfully deprives another of his property
as in this case, an ejectment case may be filed against the usurper.
RESERVATIONS
and proper.
PRAYER
WHEREFORE, plaintiff prays that the relief he prayed for in his
complaint be granted and any such other relief which the court may award to the
plaintiff which is just and equitable under the circumstances.

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567
19
POSITION PAPER
QUEZON CITY
Branch 031
JUAN AYSION SANTOS,
Plaintiff,
-versus-

JOHN CHIU CO,

Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
POSITION PAPER FOR THE DEFENDANT
this Position Paper in the above entitled case, and alleged that:
THE CASE
The case arose from the complaint filed by the Plaintiff against the
defendant on the alleged expiration of their lease agreement.
FACTS OF THE CASE
#123 Narra St., Fairville, Quezon City, where they may be served with
court order and other processes;
Quezon City where he may be served with summons, order and other
court processes;
3. Defendant was a lessee of the plaintiffs property in 129 Fairkes St.,
Fairville, Quezon City;
20

4. That defendants lease was extended 2 months ago;
5. That as a consequence of the extension, the Plaintiff allowed the
Defendant to stay for 9 months. However, the Defendant was shocked
when a couple of weeks after the extension was made, the Plaintiff is
asking him to vacate the property immediately.
be held answerable therefore;
ISSUE
1. Whether the defendant should be ejected.
2. Whether the plaintiff is entitled to damages.
ARGUMENTS
1. Under the law, where a person unlawfully deprives another of his
property, an ejectment case may be filed against the usurper
RESERVATIONS
and proper.
PRAYER
WHEREFORE, premises considered, it most respectfully prayed this
Honorable Court that the instant Case of Forcible Entry shall be dismissed for
want of basis, either in fact or in law.

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567
21
ARBITRATION / COMPROMISE AGREEMENT
QUEZON CITY
Branch 031
JUAN AYSION SANTOS,
Plaintiff,
-versus-

JOHN CHIU CO,
Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
COMPROMISE AGREEMENT
THE UNDERSIGNED PARTIES
JUAN AYSION SANTOS,
resident of #123 Narra St., Fairville, Quezon City
AND
JOHN CHIU CO,
resident of #123 Acacia St., Fairville, Quezon City
AGREE as follows:
1. That JOHN CHIU CO shall pay for the rent on the property including
back rentals;
2. The plaintiff shall drop this civil case against the defendant.
IN WITNESS WHEREOF, the Parties hereto have mutually and voluntarily
agreed to the above stipulations, and sign this Agreement, at the
METROPOLITAN TRIAL COURT of Quezon City, Branch 031, on this 16 th day of
August, 2012 for the consideration and approval of the Honorable Court.
22
JUAN AYSION SANTOS

Plaintiff
JOHN CHIU CO
Defendant
Assisted by:
JUSTIN C. BERN
Mediator
JESICA A. ASE
Mediation-Supervisor/Coordinator
23

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JUDICIAL FORMS (SUMMARY PROCEEDINGS)

EJECTMENT (FORCIBLE ENTRY)

CIVIL CASE No. Q-12345

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

ATTY. PHOEMELA G. CRUZ

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

VERIFICATION AND CERTIFICATION

JUAN AYSION SANTOS

ATTY. DAN B. SAN

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

EJECTMENT (FORCIBLE ENTRY)

CIVIL CASE No. Q-12345

DEFENDANT ADMITS the allegations in paragraph 1 and

2 DEFENDANT specifically DENIES the allegations in paragraph 5

Dismissing the complaint with costs against the plaintiff; and

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

ATTY. SHU B. SAY

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

EJECTMENT (FORCIBLE ENTRY)

CIVIL CASE No. Q-12345

JOHN CHIU CO,

ATTY. PHOEMELA G. CRUZ

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

EJECTMENT (FORCIBLE ENTRY)

CIVIL CASE No. Q-12345

JOHN CHIU CO,

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

4. The parcel of land is situated in 129 Fairville, Barangay Pangsy, City of

ATTY. PHOEMELA G. CRUZ

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

EJECTMENT (FORCIBLE ENTRY)

CIVIL CASE No. Q-12345

JOHN CHIU CO,

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

ATTY. SHU B. SAY

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

EJECTMENT (FORCIBLE ENTRY)

CIVIL CASE No. Q-12345

JUAN AYSION SANTOS

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

CIVIL CASE No. H-12346

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

VERIFICATION AND CERTIFICATION

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

JUAN AYSION SANTOS

CIVIL CASE No. H-12346

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

ATTY. SHU B. SAY

VERIFICATION AND CERTIFICATION

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

CIVIL CASE No. H-12346

JOHN CHIU CO,

ATTY. PHOEMELA G. CRUZ

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

CIVIL CASE No. H-12346

JOHN CHIU CO,

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

ATTY. PHOEMELA G. CRUZ

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

CIVIL CASE No. H-12346

JOHN CHIU CO,

JUDICIAL FORMS (SUMMARY PROCEEDINGS)

ATTY. PHOEMELA G. CRUZ