REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

BRANCH 7
ILIGAN CITY

ILIGAN CITY

Plaintiff,

-versus- CIVIL CASE No. 98765

For: COMPLAINT FOR
EXPROPRIATION
(EMINENT DOMAIN)

XANDER FORD

Defendant.

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COMPLAINT

PLAINTIFF, by counsel and to this Honorable Court, respectfully

alleges:

1. That plaintiff is a municipal corporation created by the

laws of the Republic of the Philippines, duly vested with
 the power to condemn and expropriate private property
for public use.

2. That defendant MR. XANDER FORD, is of legal age,

Filipino citizen, with postal address at White Plains St.,
Brgy. San Miguel, Iligan City, where he may be served
with summons and other legal processes by this
Honorable Court.

3. That for purpose of promoting the physical, moral and

spiritual well-being of the youth in the city, the city
council of Iligan City passed a resolution, to wit:
Resolution No. 143, providing for the construction of a
public playground in the open area of White Plains and
other adjacent areas.

4. That for the purpose of the city project, resolution

2015-110 and ordinance 06-4950 were issued.

5. That for the purpose of the said construction and public

improvement, it is necessary for plaintiff corporation to
acquire the certain parcel of land situated in Brgy. San
Miguel , City of Iligan, Philippines, and described as
follows:

“A parcel of land (Lot 23, Block 3 of the subdivision plan,

Psd-045647-056708, being a portion of Lot 1166, Cad-140
Iligan City, Cadastre LRC Record No.) situated in the #3 White
Plains, Brgy. San Miguel, Iligan City. Bounded on the NE, along
line 1-2 by Lot 22, Blk. 3, on the SE, along line 2-3 by Road Lot
8; on the SW, along line 3-4 by Lot 24, Blk. 3, on the NW., along
line 4-1 by Legal Eastment 1 all of the subdivision plan
Beginning at a point marked “1” on plan being N. 60 deg.
01W.,415.66 m. from MBM No. 53, Cad-140 Iligan City
Cadastre, thence S 45 deg. 2__E10.00 m to point 2, thence
S44 deg 39W,10.00 to point of beginning containing an area of
ONE HUNDRED SQUARE METERS, more of less. All points
referred to are indicated on the plan and marked on the ground
by P.S. cyl. Conc. Mons. 15 x 60 cm, bearing true, date of
original survey, May 1918 – July 1953, and that of the
subdivision survey. May 24-27, 1992 and was approved in
August 14, 1992.

6. That the owner of said parcel of land is defendant

Mr. Xander Ford.

7. That plaintiff has previously made a valid and definite offer

to defendant to purchase the property sought to be
expropriated but he rejected the offer.

8. That the assessed value of said property is FIVE MILLION

PESOS (P5,000,000.00).

WHEREFORE, it is respectfully prays for judgment:

1. Provisionally adjudging the value of said property in

an amount equal to the assessed value of the same.
 2. After said provisional sum is deposited by plaintiff with
the National Treasurer, awarding forthwith the
possession of the land to plaintiff.

3. After payment by plaintiff of the whole value adjudged

by this court, ordering the transfer to plaintiff of the title of
said property and prays for such further reliefs and
remedies as may be just and equitable in the premises.

October 29, 2015 at Iligan City.

ATTY. SITTIE AIYNEE M. BANGON

Counsel for Plaintiff
Until December 31, 2017
PTR NO. 6788675/04-03-00/Iligan City
IBP NO. 9874561/06-02-00/Iligan City
Roll No. 478090

VERIFICATION AND CERTIFICATION

AGAINST NON- FORUM SHOPPING

I, MARLENE YOUNG-MANGORSI, representing Iligan City,

of legal age, single, after being duly sworn to in accordance with
law, depose and says:
 1. That I am the duly authorized representative of the plaintiff
of the above-entitled case.
2. That I have caused the preparation by my counsel of
foregoing complaint.
3. That I have read the allegations therein contained, and that
the same are true and correct of my personal knowledge.
4. That I have not therefore commenced any action or filed
any claim involving the same issues in any court, tribunal, or
quasi-judicial agency and to the best of my knowledge, n such other
action or claim is pending therein; and if I should thereafter learn hat
the same or similar action or claim has been filed or is pending, I
shall report that fact within five (5) days therefrom to the court
wherein the aforesaid complaint has been filed.

Witness my hand this 29th day of October 2015 at Iligan City.

MARLENE YOUNG-MANGORSI
(Representative of Iligan City)

SUBSCRIBED AND SWORN to before me this 29th day of

October 2015, at Iligan City, affiant exhibited to me her Community
Tax Certificate No. 998654 issued on January 5, 2017, at Iligan City.

ATTY. SITTIE AIYNEE M. BANGON

NOTARY PUBLIC
 Until December 31, 2017
PTR NO. 6788675/04-03-00/Iligan City
IBP NO. 9874561/06-02-00/Iligan City
Roll No. 478090

Doc No. 31
Book No.13
Page No.26
Series of 2015