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REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION
REGIONAL TRIAL COURT
ANGELES CITY
BRANCH ____
MARTIN DESIERTO, ALAN
DESIERTO, and
FRANCIS DESIERTO,
Plaintiffs,

Civil Case No. _________________
For: Reconveyance of Real
Proprety

--versus-RODRIGO DESIERTO and RAMON
DOE.
Defendants.
x-------------------------------x

COMPLAINT
Plaintiffs, by counsel, and unto this Honorable Court, most
respectfully avers that:
1.

Plaintiff, MARTIN DESIERTO (“MARTIN” for brevity) is of

legal age, Filipino and a resident of 123 __________ where he may be
served with summons and other court processes.

Plaintiff, ALAN DESIERTO (“ALAN” for brevity) is of legal age,
Filipino and a resident of 123 __________ where he may be served with
summons and other court processes.

Plaintiff, FRANCIS DESIERTO (“FRANCIS” for brevity) is of legal
age, Filipino and a resident of 123 __________ where he may be served
with summons and other court processes.

2.

Defendant

RODRIGO

DESIERTO

(“RODRIGO”

for

brevity), is of legal age, Filipino and a resident of 124 ____________
where he may be served with summons and other court processes,

1

while defendant RAMON DOE.: VII. 8970256.0 Sometime in January 07.: 456. ALAN and FRANCIS had caused the transfer of the title of the PROPERTY in their name and was issued Transfer of Certificate of Title No. ceding unto plaintiffs MARTIN. 8970256 are attached hereto as Annexes “A” and “B” and made integral parts hereof. By virtue of the authority given by defendant RODGRIFGO. Filipino. Sometime in May 2013. Book No. A copy of the Deed of Donation and Transfer of Certificate of Title No. 12345678 in the Registry of Deeds of Angeles City (herein referred to as the PROPERTY). By virtue of the foregoing. ALAN and FRANCIS. defendant RODRIGO. permitted defendant RAMON to occupy the PROPERTY. of legal age. 8970256 is attached hereto as Annex “C” and made an integral part hereof. without the knowledge and consent of plaintiffs MARTIN. 2015 defendant RODRIGO executed a Deed of Donation duly recorded as Document No. plaintiffs MARTIN. 3. Series of 2012 in the notarial book of Atty. 2 defendant RAMON . Page No. 5. 4. Camille Jenah Banting. A copy of the Transfer of Certificate of Title No. ALAN and FRANCIS a parcel of land situated in ________ Pampanga covered by Transfer of Certificate of Title No. and a resident of 125 ____________ where he may be served with summons and other court processes.: 96. constructed therein a five-storey hotel.

stated that defendant RODRIGO gave 1 Annex “D” hereof. Despite the said letter1 dated July 02. 8.6. Outraged by the discovery of the foregoing fact. through counsel. defendant RAMON failed and refused to vacate the premises of the PROPERTY. defendant RAMON still failed and refused to vacate the premises of the PROPERTY. However they discovered that a hotel complex was being built by defendant RAMON. sent a final demand letter dated September 21. A copy of the letter dated September 21. plaintiffs MARTIN. 2014. 9. 2015. ALAN and FRANCIS. 2014. ALAN and FRANCIS. 10. 11. 7. Defendant RAMON. Despite said letter2 dated August 22. Sometime in June 2014. ALAN and FRANCIS. ALAN and FRANCIS went to survey the PROPERTY for their plan to build a fivestorey hotel. sent another letter dated August 22. A copy of the letter dated August 22. 2014. plaintiffs MARTIN. By reason thereof. 2014 is attached hereto as Annex “E” and made an integral part hereof. sent a letter dated July 02. demanding defendant RAMON to vacate the PROPERTY and to pay reasonable rent and damages for the use of the said property. 2 Annex “E” hereof. demanding that defendant RAMON vacate the PROPERTY. 3 . sent a letter dated October 31. demanded that defendant RAMON vacate the PROPERTY and restore it to its original state. By reason thereof. plaintiffs MARTIN. A copy of the letter dated July 02. plaintiffs MARTIN. 2014 is attached hereto as Annex “F” and made an integral part hereof. 2015. through counsel. 2014. In reply thereto. 2014 is attached hereto as Annex “D” and made an integral part hereof.

him permission to use the PROPERTY and an alleged Deed of Absolute Sale was executed by the latter ceding to defendant RAMON the said property. ALAN and FRANCIS further reiterated their demand that defendant RAMON vacate the PROPERTY. ALAN and FRANCIS of the PROPERTY. A copy of the letter date October 31. 2014. 2015 is attached hereto as Annex “G” 12. In the same letter. 4 . 14. 8970256. defendant still failed and refused to heed to the demands of the former. through counsel. A copy of the letter dated November 16. plaintiffs MARTIN. sent a letter dated November 16. plaintiffs MARTIN. controverting defendant RAMON’s claim and furnishing him a copy of TCT No. ALAN and FRANCIS. 2014 is attached hereto as Annex “H” and made an integral part hereof. Consequently. 13. Despite the knowledge of Defendant RAMON of the ownership of plaintiffs MARTIN.