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Complaint Recovery of Possession
Complaint Recovery of Possession
RONELO C. CALUGAS,
Plaintiff, Civil Case No. 1125-16-
4816
ROMEL A. DILAG,
Defendant.
COMPLAINT
4. That adjoining plaintiffs land on the Northeast side along lines 3-4-5-6
is Lot no. 1451-A owned by the defendant;
7. That far from complying with plaintiffs valid and just demands,
defendant did not stop the construction of a concrete fence along
South Eastern side of plaintiffs land instead, defendant erected a shed
inside Lot No. 1451-B;
1. That the plaintiff is entitled to the relief demanded and the whole
or part of such relief consist in ordering the defendant to deliver
to the plaintiff possession of the land subject of this case which is
described under paragraph 3 of the complaint.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court that pending final judgment, a writ of preliminary
mandatory injunction be issued ordering the defendant to vacate and deliver
to the plaintiff the land described under paragraph 3 of the complaint and
after due hearing making the injunction permanent and further after due
notice and hearing, judgment be rendered in favor of the plaintiff, as follows:
1. Ordering the defendant demolish and/or to remove at his
expense whatever structure he caused to be constructed
on Lot No. 1451-B and also to demolish and/or remove
the concrete fence constructed on the South Eastern side
of Lot No. 1451-B which is described under paragraph 3 of
this complaint.
Such other relief and remedy which this Honorable Court may
deem just and equitable is likewise prayed.
VERIFICATION/CERTIFICATION
I, RONELO C. CALUGAS, Filipino, of legal age, single, and a resident of
Providence Subd., Brgy. Balabag, Pavia, Iloilo, after having been duly sworn in
accordance with law, depose and say:
1. I am the defendant in the above-entitled case;
3. I have read and understood the contents of the same and that the
allegations stated therein are true and correct to the best of our
personal knowledge and based on the authentic records;
4. That hereby certify that at the time of the filing of this Complaint, I
have not commenced any other action involving the same issues in
the Supreme Court, the Court of Appeals, or any other tribunal or
agency; that to the best of my knowledge, no such action is pending
or was terminated in the Supreme Court, similar action has been
filed or is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency wherein the original pleading and
sworn certification has been filed.
IN WITNESS WHEREOF, I have hereunto affixed my signature this _____ day of
_______, 2014 at Iloilo City, Philippines.
RONELO C. CALUGAS
Affiant
JURAT/NOTARIAL CERTIFICATE
The principal/affiant whose name and personal circumstances are
stated above appeared in person before me this 5th day of June, 2014 in the
City of Iloilo, presented the foregoing verification/certification, signed the
same in my presence, and affirmed or swore under oath to the truth and
correctness of the contents or allegations of the same.
The principal/affiant is personally known to me and they exhibit to me
his Drivers License No. 00423768 issued on May 28, 2012 at LTO Office,
Iloilo City.