REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION

Municipal Circuit Trial Court
Branch __
Labrador-Sual, Pangasinan

Spouses Benito Dulay

and Leonida Dulay
Plaintiffs,
Civil Case No. _______________
-versus- For: Recovery of Possession and
Damages
Rufina Dulay-Martin
Respondent.
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COMPLAINT
PLAINTIFFS, through counsel and to this Honorable Court, respectfully avers that:
1. Plaintiffs are of legal age, both Filipino, married to each other, and both
residents of Poblacion, Sual, Pangasinan, where they may be served with
notices and other court processes, in addition to or in lieu of their counsel’s
address;
2. Defendant is of legal age, Filipino, and a resident of 374 Tactacquin Street.,
Poblacion, Sual, Pangasinan, where she may be served with summons,
notices, orders and other court processes that this Honorable Court may
issue;
3. Plaintiffs are the owners of a parcel of residential land containing an area
of 24 sq. m., more or less located in Poblacion, Sual, Pangasinan, now being
held by defendant;
4. The said parcel of land was purchased by the Plaintiffs from a certain Julieta
Veluz-Marcos on February 3, 2010, photocopy of the Deed of Absolute Sale
attached herewith and made an integral part hereof as ANNEX “A”;
5. The subject parcel of land was declared in the name of the Plaintiffs for tax
purposes under Tax Declaration No. 6578, Property Index No. 013-41-001-17,
issued by the Assessor’s Office in Lingayen, Pangasinan, certified copy
attached herewith and made an integral part hereof as ANNEX “B”;
6. Plaintiff has been paying the real property taxes of the subject parcel of
land since 2011 up to the present as evidenced by Official Receipts hereto
attached and marked as Annex “C”;