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Republic of the Philippines

REGONAL TRIAL COURT


11th Judicial Region
Branch 8, Davao City
Captain America
Plaintif
Sale
Damages
Versus

Civil Case No. 2341521-64


For: Annulment of Deed of
Reconveyance and

Iron Man
Defendant
x--------------------------x
COMPLAINT
Plaintif by the undersigned counsel, respectfully alleges:
1. That the plaintif, Captain America, is of legal age, single, Filipino
citizen and a
resident of #13 Jacinto Street, Barangay 32-D, Poblacion, Davao
City.
2. That the defendant, Iron Man, is of legal age, single, Filipino
citizen and a
resident of #75 Mahogany street, Hillside Subdivision, Lanang,
Davao City where he may be served with summons and other court
processes.
3. That the plaintif is the lawful owner of a lot with Lot No. 2221,
Psd-05
103024 covered by Original Certificate of Title No. 3782 situated in
Purok 30 KM. 6, Maa Highway, Davao City, Davao del Sur consisting
of Ten Thousand (10,000) square meters with an assessed value of
more or less Ten Million Pesos ( P 10,000,000-);
4. That the plaintif obtained a loan from defendant in which the
defendant
required the title certificate of the above mentioned lot to be
handed to him for safe keeping without executing a real estate
mortgage contract;
5. That the above mentioned lot is the subject of the Deed of
Absolute Sale

dated January 5, 2014 in favor of the defendant by virtue of which


Transfer Certificate of Title No. T-21382 dated January 10, 2015 was
issued in favor of the defendant;
6. That the plaintif never signed the said Deed of Absolute Sale
and the
signature of the plaintif appearing therein is forged;
7. That by reason of the forged deed of sale and the transfer
certificate of title
covering the above mentioned lot, the plaintif was compelled to
institute this action engaging the services of a counsel in the
amount of P50, 000 as attorneys fees.
Wherefore, premises considered, it is most respectfully prayed
that judgment be rendered:
1. CANCELLING Transfer Certificate of Title No. T-21382 in the name
of Iron Man;
2. ANNULLING the Deed of Absolute Sale date January 5, 2016 in
favor of Iron Man;
3. ORDERING the defendant to reconvey the subject lot to plaintif;
4. ORDERING defendant to pay attorneys fee in the amount of P50,
000
Plaintif further prays for such other reliefs and remedies deemed
just and
proper under the premises.
City of Davao, Philippines, April 11, 2016.

RAZEL MAY M. RAMON


Counsel for the Plaintif
c/o A&A and Associates Law
Veterans Building, Monteverde,Davao
City
IBP No. 947555/ 1-02-14/ Davao
City
PTR No. 7150933// 1-02-14/ Davao
City

Roll No. 77777


MCLE Compliance No. IV-0079772
March 21, 2013
Telephone No. (082) 285-7717
Republic of the Philippines)
City
of
Davao) Sc.
x-------------------------------------------x
VERIFICATIONANDCERTIFICATIONOFNONFORUMSHOPPING
I,CaptainAmerica,oflegalage,afterhavingbeendulysworninaccordancewithlaw,
deposeandstatethat:
1.Iamaplaintiffintheabovestatedcase;
2.Icausedthepreparationoftheforegoingcomplaint;
3.Ihavereadthecontentsthereofandthefactsstatedthereinaretrueandcorrectofmy
personalknowledgeand/oronthebasisofcopiesofdocumentsandrecordsinmy
possession;
4.Ihavenotcommencedanyotheractionorproceedinginvolvingthesameissuesinthe
SupremeCourt,theCourtofAppeals,oranyothertribunaloragency;
5.Tothebestofmyknowledgeandbelief,nosuchactionorproceedingispendinginthe
SupremeCourt,theCourtofAppeals,oranyothertribunaloragency;
6.IfIshouldthereafterlearnthatasimilaractionorproceedinghasbeenfiledoris
pendingbeforetheSupremeCourt,theCourtofAppeals,oranyothertribunaloragency,
Iundertaketoreportthatfactwithinfive(5)daystherefromtothisHonorableCourt.

CaptainAmerica
Affiant

SUBSCRIBEDANDSWORNtobeforemethis___dayof__________200_
at_________________affiantexhibitingtomehisCommunityTaxCertificate
No.____________________issuedon________________200_at______________
City.

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