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Republic of the Philippines

National Capital Judicial Region


METROPOLITAN TRIAL COURT
Branch 33, Paranaque City

HEIRS OF VITO S. CORLEONE,


Represented by:
Michael Corleone,
Plaintiffs,

-versus-

Civil Case No. 0712992


For: UNLAWFUL DETAINER

SPS. BRUNO TATTAGLIA &


MARIA TATTAGLIA,
Defendants,
xxx----------------------------------------------------xxx
COMPLAINT

COMES NOW, the plaintiffs, through the undersigned


counsel and unto this Honorable Court, most respectfully avers
that:

1. The Plaintiffs are of legal age, and a resident of St.Mary,


Sampaloc, Manila City.
2. Defendant Spouses are both of legal age, and a resident of
Petersville Subdivision, Paranaque City where they may be
served with summons;
3. Plaintiffs-siblings, Santino Corleone, Constancia Manzinni and
Michael Corleone are the lawful owners of the house and lot
located at Petersville Subdivision, Paranaque City, which was
sold to the Defendant spouses on January 2006 as evidenced
by an Absolute Deed of Sale at the amount of two million and
five hundred thousand pesos;

4. The defendant spouses were allowed to take over the house


and lot, however the title shall only be transferred upon the
payment of balance worth three hundred thirty-eight thousand
pesos;
5. Noncompliance of the Defendant Spouses to pay the remaining
balance after a written demands made on August 02, 2010 and
April 15, 2013, the Plaintiff revoked the deed of absolute sale;
and in addition to this, the latter also ordered the former to
vacate the premises and to pay for monthly rentals;
6. Due to Defendant Spouses adamant refusal to vacate the
premises, the plaintiff suffered sleepless nights as well as
mental anguish, hence, was constrained to initiate the suit and
to incur expenses aside from costs of suit;
7. Prior to the filling of this complaint, this dispute was brought to
the Lupong Tagapamayapa of Barangay Petersville
Subdivision, Paranaque City, where the premises is located,
but no settlement was arrived at, as evidenced by the
Certificate to file Action issued by the Barangay Chairman, a
copy of which is hereto attached.

WHEREFORE, it is respectfully prayed that, after due hearing,


judgment be rendered, ordering the defendant spouses to vacate the
premises and shall be ordered to pay the rentals, damages and
attorneys fees.
Plaintiff prays for such other and further relief as may be just
and equitable under the premises is likewise prayed for.
Manila City, Philippines, February 27, 2014.
CHERRY RHOSE M. CUREG
Counsel for the Plaintiff
1901 Mindanao Ave. cor. Palawan St.,
Sampaloc, Manila, Philippines; (0927) 613-7049
(02) 715-58-90

IBP-071292, July 07, 2010; Quezon City


PTR NO. 232808 July 12, 2011; San Juan City
Roll of Attorneys No. 92071
MCLE Compliance No. III-111234, 13 June 2011
TIN-098-7655

VERIFICATION AND CERTIFICATION OF NON-FORUM


SHOPPING
I, MICHAEL CORLEONE, of legal age, Filipino citizen, single
and resident of St. Mary Street, Manila, after having been duly sworn
to in accord with law do hereby depose and state:
1. That I am the representative of the plaintiffs in the above-entitled
case;
2. That I have caused the preparation of the foregoing complaint and
have read the allegations contained therein; and the allegations in the
said complaint are true and correct of my own knowledge and
authentic records;
3. That I hereby certify that I have not commenced any other action or
proceeding involving the same issues in any court, tribunal or quasijudicial agency and, to the best of my knowledge, no such other
action or claim is pending therein;
4. That if I should learn thereafter that a similar action or proceeding has
been filed or is pending, I hereby undertake to report that fact within
five (5) days there from to the court or agency where the original
pleading and sworn certification contemplated herein have been filed;
5. That I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular No.
04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature
this 27th of February 2014, in the City of Manila.

MICHAEL CORLEONE
SUBSCRIBED AND SWORN to before me this 27th day of
February, 2014, in the City of Manila, affiant exhibiting to me his
Drivers License No. 12345 issued by the Land Transportation Office
on April 8, 2012 at the City of Manila.
SOL M. CARPIO
Notary Public
My Commission Expires Dec.25, 2014
Roll of Attorney No. 23290
IBP No. 920112/2-3-09/Manila
PTR No. 7155890/02-01-12/Manila

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