ses OOK COMPLAINT COME NOW, plaintiffs by undersigned counsel and unto this Honorable Court, most respectfully allege: 1. Plaintiffe spouses, both of legal age, Filipino citizens, and presently residing at #349 Jasmin St., Nieves Hills Subdivision, San Isidro, Angono, Rizal; Defendants Sps. Ryan F. Ronquillo and Agnes Ronquillo, are likewise of legal ages, Filipino citizens, and with residence at #349 Jasmin St, Nieves — Hills Subd., San Isidro, Angono, Rizal, where they may be served will ‘Summons and other court processes; $e Defendant God's World Christian Fellowship (GWCF}, is « sect. with place of worship at #349 Jasmin St., Nieves Hills Sub 3 Angono, Rizal, where it may be served with Summons and processes through Defendants spouses above-mentioned; 2. Plaintiffs are the lawful and registered owner of a covered by Transfer Certificate of Title No. 689014, issued by # Deeds for the Province of Rizal, on May 12, 2004, a copy hereto attached to form integral part of this3. The plaintiffs being the owners and in possession of the said property, have been the ones paying the real estate taxes under Tax Declaration No, 00- ‘A-006-11400 for the land and Tax Declaration No. 00-A-006-12140 for the ‘house, they have occupied the same from the beginning, the latest payment ‘being covered by Official Receipts Nos. 0607587 dated January 28, 2013, ‘O.R No. 8786641 dated February 20, 2011, 0.R Ne. 0502895 dated February 2, 2011, O.R No. 0421475 dated January 27, 2010, O.R No. 0394050 dated March 13, 2009, ©.R No, 0347144 dated March 4, 2008, O.R No. 0307242 dated January 12, 2007, 0.R No. 0249626 dated January 6, 2006, 0.R No. 0158463 dated January 17, 2005, 0.R No. 0038618 dated January 2, 2003, and O.R No. 8171883 dated January 3, 2002, certified copy of the Tax Declarations and machine copies of the Official Receipts of payment of taxes are hereto attached to form integral parts hereof as Annexes “B”, “C” and “D" to *D-10", respectively; 4. Plaintiffs allowed the defendants to occupy portion of the parcel of land subject of this case subject to certain conditions, consisting an area of ONE HUNDRED FORTY TWO (142) SQUARE METERS which occupation became unlawful and illegal; 5. Being the legal and registered owners of the subject property, plaintiffs are seeking to recover the possession of that portion or premises being occupied by defendants; 6. Plaintiffs through their present counsel sent a final demand letter to the defendants dated February 11, 2013, demanding the latter to vac premises and to remove the improvements thereon, a copy of the final letter with Return Receipt dated February 11, 2013 is hereto att Annex “E” and “E-1"; 4 7. Despite defendants receipt of the written demand plaintiffs, defendants refused to leave the subject premises, p the matter to the office of the Barangay conciliation settlement; 8. However, due to failure of settlement, the Office 0 conciliation Isidro, Angono, Rizal was constrained to issu Makadulog sa Hukuman” a machine copy of the as Annex “I© Defendants have been illegally and unlawfully occupying the subject premises as their residence and as place of worship for members of the defendant GWCF 10, Por taiture and continuous refusal of the defendants and other Persons claiming mghta under them, to leave the premises aforementioned. plaintiffs were constrained to hire the services of counsel and have agreed to Pay Thirty Thousand Pesos (P30,000} as attorney's fee and One Thousand Five Hundred (P1,S00} per court appearance; 11. Defendants’ refumal to vacate the premises has deprived the plaintiffs of thetr rights of possession to subject premises, a reasonable value for the use of the occupied premises would not be less than THREE THOUSAND PESOS: (P3,000.00) « month, starting from the time that their occupation became unlawful; RAYER WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court that after due hearing, judgment be rendered in favor of the plaintiffs and against defendants, as follows =. Ordering the Defendants and all persons claiming rights from the latter to vacate the subject premises and removed all the improvements: thereon at their expenses: bb. To pay the Plaintiffs jointly and severally, the amount of Thousand (P50,000.00) Pesos, as reasonable equivalent rental for’ cccupation of the subject property from the time of the receipt! Defendants of the demand to vacate and those that will accrue th €. Ordering the Defendants to pay jointly and severally the Fifty Thousand (P50,000.00) Pesos to the Plaintiffs for and attorney's! Thirty Thousand (P30,000.00) Pesos as expenses litigation; 3 @. Ordering Defendants to pay cost and suit, Other relief, just and equitable is likewise prayed for. Binangonan, Rizal. March 12, 2013VERIFICATION AND CERTIFICATION We, OPS. RFREN R. TEODORO and CELIA A. TEODORO, of legal agen, Filipino citizens and residents of #349 Jasmin St., Nieves Hills Subd., San Isidro, Angono, Rizal, after having been duly sworn to in accordance with law, depose and state: h ‘That we are the complainants in the above-entitled case; ‘That we caused the preparation of the foregoing Complaint for Ejectment /Uniawful Detainer; ‘That we have read the contents thereof and affirm that the allegations therein are true and correct to our own personal knowledge and based on authentic records; That we certify that we have not commenced any similar or other action involving the same issues or cause of action before the Supreme Court, Court of Appeals, or any court or administrative body; That a case for a Plenary action for Recovery of Possession was decided with Finality by the Supreme Court alleging among others that the case in for Unlawful Detainer and should be filed before the MTC Angono, Rizal. That we hereby undertake that in event that we should hereafter learn that an action involving similar case is filed, or pending before the Supreme Court, the Court of Appeals or other court, tribunal or agency, we shall immediately inform Honorable Court of such fact within five (5) days from thereof, IN WITNESS WHEREOF, we have hereunto set our affixed our signatures. below Complainant 0 Bn = = 000 145 tener besviw cine SUBSCRIBED AND SWORN to before HAR 3 gy at Binangen aes Doc, No. IHS; Page No, 28; Book No, th; Series of 2013LEONARDO C. ASEOCHE Al \ttorney-At-Law wy” catl229 Manila East Road E lumpang Binangonan, Rizal ne (near Municipal Building) pnet Contact Nos. 289-4784 / 658 9818/09 156722953 RYAN RONQUILLO and AGNES RONQUILLO, GCWr, all persons claiming rights under ther #349 Jasmin St, Nieves Subdivision San Isidro, Angono, Rizal FINAL DEMAND Dear Mr, and Mrs. Ronquillo, and all persons claiming rights under them, In accordance with the decision of the Honorable Supreme Court, denying the Petition for Review of the decision of the Honorable Court of Appeals reviewing the decision of the Regional Trial Court, and stating with finality that the proper action is one of Ejectment/Uniawful Detainer, we therefore demand from you to vacate the property subject of this action ¢ are giving you Ten (10) days from receipt of the demand to vacate the premises and surrender the lawful possession of this property to herein Spouses Efren and Celia Teodoro. Failure on your part will constrain the spouses to file the necessary Ejectment suit against you. Thank you and good day Otudeg by CB 2. eoime EFREN R. TEODORO —- CELIA A. TEODORO.Ps _ . i Lani a es BAYAN WG ANGO BARANGAY SAN IsIDRO TANGGAPAN NG FUNONG BARANGAY ee KATIBAYAN UFANG Basa : Usaping Brgy Big 95-92 _ Lm Meee Hille tae ? 1 Ble ed £8 May sienna) = Ex aaa Auwex (iden ininmpsurnbona) fie, Aogeor, Mana Hey hingpapmiioniy tm o |e TL ba ‘Adi (orga) ipitngeumborg, si pasrom max, : : a ay sadyang di-tumupad atsi PASTOR — 2 ing ranggl 8a patAwaR 0 88 paZharap s8 pos (ows rg ghana (Afi pameanyo ay itinatrws ay teeesi nang idalog 1a somes Haya't ari baailang sumbony who! sa alnan oy a ionmeapen * ow ng Abr aa Hgevon thee, 2908 arewng Avril ‘Kali ng Lupon /Pangkat tu MAHALAGA: ayn 7 Ks Lapin ny quran og atayan, ang Taye Pongul rg patunay Kepag tog Kalihim ng Paghai ang gumane ng batibayan, ang eaters amassee Se AEPORLIC OF THE PHILIPPINES COURT OF APPEALS Manila 1, TERESITA R. MARIGOMEN, Clerk of Court of the Court of Appeals, do hereby certify that | have examined the herein document to wit: A CERTIFIED photocopy ofthe “EXHIBITS “i (Katibayan Upang Makadulog sa Hukuman, dated April 13, 2003) found on page/s 131 in the Tokder ofthe Orgiral Records. of Civil Case No. 06-005 of the Regional Trial Court of Binangonan, Rizal, Branch 69 docketed with this Court as CA-GR. No. C¥- 93699. entitled: SPOUSES EFREN R. TEODORO and CELIA TEODORO, versus RYAN F. RONQUILLO and AGNES F. RONQUILLO, ET AL, consisting of One (1) page/s only. NOTE: This certification is not valid without the signatures of the Proofreaders and Veritiers as well as the seal of the Court in each and every page of this document. IN WITNESS WHEREOF, I have hereunto signed my name and affixed the seal of this Court this 19th day of March, 2013. TERESITA R. MARIGOMEN Clerk of Court DOCUMENTARY STAMP O.R. No.: 7397880 A Date: March 19, 2013 Paid OLR. Nos.: 38/6171 B& 3823034 B Date; March 19,2013 Issued upon the request: Agnes Ronquillo NOTE: Not valid without Official Receipts