Sample Forcible Entryejectment

JUDICIAL FORMS (SUMMARY PROCEEDINGS)
EJECTMENT (FORCIBLE ENTRY)

COMPLAINT
Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION
METROPOLITAN TRIAL COURT
QUEZON CITY
Branch 031
JUAN AYSION SANTOS

Plaintiff,
-versus- CIVIL CASE No. Q-12345

For: EJECTMENT (FORCIBLE ENTRY)
JOHN CHIU CO
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
COMPLAINT
PLAINTIFF, through the undersigned counsel, and unto this Honorable

Court most respectfully submits this Complaint for Forcible Entry and in support
hereof makes the following assertions:
1. Plaintiff JUAN AYSION SANTOS, is residing at #123 Narra St.,

Fairville, Quezon City, where he may be served with court order and other
processes;
2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville,

Quezon City where he may be served with summons, order and other court
processes;
3. Plaintiff became owner of a certain parcel of land, through a Deed of Sale

from the original owner, JANICE DY LEE. (A copy of the Deed of Sale
is hereto attached as Annex “A”);
4. The parcel of land, situated in #129 Fairville, Barangay Pangsy, Quezon

City, is covered by Transfer of Certificate of Title No. 12345 issued by the
Register of Deeds od Quezon City and is more particularly described, as
follows:
(Description)
(Copy of TCT- 12345 is hereto attached as ANNEX “B”);
5. Herein Defendant, through stealth and strategy, occupied the parcel of

land in question and refuses to vacate the same despite repeated oral and
written demands. (Copy of the written demand is hereto attached as
Annex “C”);
6. The same acts of the Defendant compelled the Plaintiff to incur damages
consisting of attorney’s fees in the amount of Thirty thousand pesos
(P30,000.00) pesos and filing fee, cost of transportation and other
1
miscellaneous accommodation of its lawyers and other personal expenses

to be incurred in attending the hearings of this case in the amount of
FIFTY THOUSAND PESOS (Php 25,000.00).
7. This action is governed by the Rules on Summary Procedure;
PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court that, after the proceedings, judgment be rendered in favor of
the Plaintiff and ordering the Defendant and all persons claiming rights under
him to:
(a) Permanently VACATE the premises in question and give the immediate
right of possession to the Plaintiff;
(b) Pay plaintiff the amount of Thirty Thousand Pesos (P30,000.00) by way
of attorneys fees and Twenty Five Thousand Pesos (P25,000.00), by way
of other litigation expenses; and,
(c) Pay the cost of this suit.
Plaintiff prays for such other remedies and reliefs as may be deemed just and
equitable under the premises.
May 1, 2011. Quezon City, Metro Manila.
ATTY. PHOEMELA G. CRUZ

Counsel for Plaintiff
Quezon City
Roll of Attorneys No. 1234567
IBP No. A-1234567
PTR No. A- 1234567
MCLE No. A-1234567
2
VERIFICATION AND CERTIFICATION

AGAINST NON- FORUM SHOPPING
I, JUAN AYSION SANTOS, of legal age, after being duly sworn to in

accordance with law, depose and attest:
That I am the petitioner in the above-titled case; that I have caused the
preparation of the foregoing petition and understood the contents thereof, and I
hereby declare that all the allegations contained therein are true and correct
according to my knowledge and belief.
Furthermore, I hereby certify that I have not filed nor caused to be filed
any other similar case involving the same issues in the Supreme Court, Court of
Appeals or any other tribunal or agency and that, should there be any other such
case/s that may have been filed, I hereby bind myself to inform the Court of such
fact within five (5) days from the discovery thereof.
IN WITNESS WHEREOF, I have hereunto set our hand this 1st day of
May 2012, City of Quezon, Metro Manila, Philippines.
JUAN AYSION SANTOS

Affiant
CTC No. 1234565
Issued On: May 4, 2011
Issued At: Quezon City
SUBSCRIBED AND SWORN to before me, in the City of Quezon, this

1st
day of May 2012, City of Quezon, Metro Manila, Philippines, affiant having ex
habited to me his Drivers License No. ___________, issued at Quezon City,
Philippines.
ATTY. DAN B. SAN

Notary Public
Until December 31, 2013
PTR No. A-123056
Issued at Quezon City
On January 1, 2012
Doc. No. 1;
Page No. 1;
Book No. 1;
Series 2012.
3

ANSWER

QUEZON CITY
Branch 031
JUAN AYSION SANTOS,

Plaintiff,

JOHN CHIU CO
Defendant.
x- - - - - - - - - - - - - - - - - - - - - - - - x
ANSWER
COMES NOW THE DEFENDANT JOHN CHIU CO, through the

undersigned counsel, and unto this Honorable Court most respectfully submits
that:
1. DEFENDANT ADMITS the allegations in paragraph 1 and

paragraph 2 of complaint insofar as they relate to their personal
circumstances;
2. DEFENDANT specifically DENIES the allegations in paragraph 5

since he was given authority by JANICE DY LEE to occupy the
land.
PRAYER
WHEREFORE, the answering defendant, most respectfully pray

for judgment:
1. Dismissing the complaint with costs against the plaintiff; and
2. The Defendant’s further pray for any and all relief and remedies
fitting and proper under the premises.
4
City of Quezon, June 01, 2012
ATTY. SHU B. SAY

Counsel for Defendant
Quezon City
Roll of Attorneys No. A-123467
IBP No.A-123456
PTR No. A-1234557
MCLE No. A123457
VERIFICATION
I, JOHN CHIU CO, Filipino, of legal age, and residing at 123 Acacia St.,
Fairville, Quezon City, Metro Manila after having been duly sworn in accordance
with law, hereby depose and state that I, the defendant in the present case;
caused the preparation of the foregoing Answer; that I have read and understood
the contents thereof and that the same are true and correct as to the best of our
knowledge and belief.
City of Quezon, June 01, 2012
JOHN CHIU CO
Defendant
CTC No. B-124843
On March 3, 2012
Copy furnished:

Quezon City
5

REPLY

QUEZON CITY
Branch 031
JUAN AYSION SANTOS,

Plaintiff,

JOHN CHIU CO,

Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
REPLY
COMES NOW Plaintiff through the undersigned counsel and hereby

respectfully states that:
1. In the Defendant’s Answer, the said defendant stated that plaintiff allowed
him to use the premises of the lot;
2. Defendant is evidently misleading the court in denying the existence of the

cause of action;
PRAYER
WHEREFORE, Plaintiff respectfully prays that judgment be rendered in his

favor in accordance with the original prayer set forth in the plaintiff’s complaint.
Quezon City. May 4, 2012

Quezon City
IBP No.A-1234567
6
PTR No. A-12345567

MCLE No. A1234567

POSITION PAPER

QUEZON CITY
Branch 031
JUAN AYSION SANTOS,

Plaintiff,

JOHN CHIU CO,

Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
POSITION PAPER FOR THE PLAINTIFF
PLAINTIFF, by counsel, unto this Honorable Office, respectfully submits

this Position Paper in the above entitled case, and alleges that:
THE CASE
The case arose from the stealthy strategic usurpation of the defendant of
the property of the herein plaintiff. Plaintiff now prays for the ejectment of the
defendant and the payment of damages.
FACTS OF THE CASE
1. Plaintiff JUAN AYSION SANTOS, is a resident of #123 Narra St., Fairville,

Quezon City, where they may be served with court order and other
processes;

Quezon City where he may be serve with summons, order and other court
processes;
3. Plaintiff became owners of a certain parcel of land, through a Deed of Sale

from the original owner, JANICE DY LEE.
7
4. The parcel of land is situated in 129 Fairville, Barangay Pangsy, City of

Quezon, Metro Manila covered by TCT No. 12345.
5. That herein Defendant, through stealth and strategy, occupied the parcel
of land in question.
6. That Defendant, despite repeated demand, refused to vacate the land.
7. The same acts of the Defendant compelled the Plaintiff to incur litigation
expenses consisting of attorneys fees in the amount of THIRTY
THOUSAND (Php 30,000.00) and other litigation expenses consisting of
filing fees, cost of transportation and other miscellaneous expenses to be
incurred in attending the hearings of this case at TWENTY FIVE
THOUSAND PESOS (Php 25,000.00).
ISSUE
1. Whether or not defendant should be ejected.
2. Whether or not plaintiff is entitled to damages.
ARGUMENTS
1. Under the Rules of Court, where a person unlawfully deprives another of

his property, an ejectment for forcible entry case may be filed against the
usurper
2. Under the Civil Code, the plaintiff is entitled to moral and actual damages.
RESERVATIONS
Plaintiff respectfully reserves its right to file supplemental pleadings or

adduce additional evidence in due course of the proceedings whenever necessary
and proper.
PRAYER
WHEREFORE, plaintiff prays that the reliefs prayed for in the instant
complaint be granted.

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567
8

POSITION PAPER

QUEZON CITY
Branch 031
JUAN AYSION SANTOS,

Plaintiff,

JOHN CHIU CO,

Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
POSITION PAPER FOR THE DEFENDANT
DEFENDANT, by counsel, unto this Honorable Office, respectfully

submits this Position Paper in the above-titled case, and alleges that:
THE CASE
The is an action for Forcible Entry commenced by the Plaintiff JUAN

AYSION SANTOS against the defendant JOHN CHIU CO. The subject matter
of this action is a piece of land identified as in #129 Fairville, Barangay Pangsy,
City of Quezon, Metro Manila. Copy of TCT- 12345 Lot No. 2-A-1 situated at
Barangay Pangsy, City of Quezon under OCT No.123456 issued in the name of the
late JUANA DELA CRUZ -SANTOS registered in the Registry of Deeds of Quezon
City.
FACTS OF THE CASE
1. Plaintiff JUAN AYSION SANTOS, with residence and postal address at

#123 Narra St., Fairville, Quezon City, where they may be served with
court order and other processes;

processes;
3. Plaintiff became owner of a certain parcel of land, through a Deed of Sale

from the original owner, JANICE DY LEE Copy of the Deed of Sale is
hereto attached as Annex “A”;
9
4. The parcel of land is situated in #129 Fairville, Barangay Pangsy, City of

Quezon, Metro Manila. Copy of TCT- 12345 is hereto attached as ANNEX
“B”;
5. That as early 2002, JOHN CHIU CO took possession of the property under
Lot No. 2-A-1 and constructed a nipa hut thereon.
6. On April 15, 2012 the defendants were surprised that plaintiff JUAN
AYSION SANTOS approached and informed him that he was the lawful
owner of the land and they acquired it through a sale because their mother
never sold the said property when she was alive.
7. On May 19, 2012 the defendant received a summon from the Metropolitan
Trial Court to answer for a complaint filed against them for forcible entry.
On June 1, 2012 the defendant thru the undersigned counsel filed an
answer to the complaint.
8. The same acts of the Plaintiff compelled the Defendant to incur litigation
expenses consisting of filing fee, cost of transportation and other
to be incurred in attending the hearings of this case, etc., fixed at FIFTY
THOUSAND PESOS (Php 50,000.00), which the Plaintiff should also be
held answerable therefore;
ISSUE
1. Whether the defendants can be ejected by forcible entry under Rule 70

Section 1 of the Revised the Rules of Court.
ARGUMENTS
1. The defendants cannot be ejected on the subject land for the reason that
for forcible entry to attach the following circumstance must concur:
(a)That the person is deprived of his property;
(b)That such deprivation is due to force, intimidation, threat, strategy or

stealth; and
(c)That such person has real title over such property.
In this case, the Defendant made no deprivation of possession on the

Plaintiff because the property was already in his possession and the
plaintiff started to claim such land on April 2012 based on the alleged sale
of JANICE DY LEE to the Plaintiff. This would only show that
defendant was in a threat of losing the subject land which they lawfully
acquired through the permission of JANICE DY LEE.
Moreover the plaintiff has never been in possession of such land from the
time it was acquired by the defendants. This means that plaintiff was never
in possession of the property as one of the elements of forcible entry.
RESERVATIONS
10

and proper.
PRAYER
WHEREFORE, defendant prays that the reliefs he prayed for in his

complaint be granted and any other reliefs which the court may award to the
plaintiff which is just and equitable under the circumstances.
ATTY. SHU B. SAY

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567
11

ARBITRATION / COMPROMISE AGREEMENT

QUEZON CITY
Branch 031
JUAN AYSION SANTOS,

Plaintiff,

JOHN CHIU CO ,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
COMPROMISE AGREEMENT
THE UNDERSIGNED PARTIES
JUAN AYSION SANTOS,

resident of #123 Narra St., Fairville, Quezon City
AND
JOHN CHIU CO,

resident of #123 Acacia St., Fairville, Quezon City
AGREE as follows:
1. That JOHN CHIU CO shall pay for the rent on the property including
back rentals;
2. The plaintiff shall drop this civil case against the defendant.
IN WITNESS WHEREOF, the Parties hereto have mutually and voluntarily

agreed to the above stipulations, and sign this Agreement, at the
METROPOLITAN TRIAL COURT of Quezon City, Branch 031, on this 15th day of
July, 2012 for the consideration and approval of the Honorable Court.
JUAN AYSION SANTOS JOHN CHIU CO

Plaintiff Defendant
Assisted by:
12
JUSTIN C. BERN JESICA A. ASE

Mediator Mediation-Supervisor/Coordinator
E J E C T M E N T (UNLAWFUL DETAINER)
COMPLAINT

QUEZON CITY
Branch 031
JUAN AYSION SANTOS

Plaintiff,
-versus- CIVIL CASE No. H-12346

For: EJECTMENT (UNLAWFUL DETAINER)
JOHN CHIU CO
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
COMPLAINT
PLAINTIFF, through the undersigned counsel, and unto this Honorable

Court most respectfully submit this Complaint for Unlawful Detainer and in
support hereof makes the following assertion:
1. Plaintiff JUAN AYSION SANTOS’s residence and postal address is at #123

Narra St., Fairville, Quezon City, where they may be served with court
order and other processes;
2. Defendant JOHN CHIU CO residence and postal address is at #123 Acacia

St., Fairville, Quezon City where he may be served with summons, order
and other court processes;
3. Initially, the possession of property located at 129 Fairkes St., Fairville,

Quezon City by the defendant was by a contract of lease with or by
tolerance of the plaintiff;
4. That defendant’s lease expired 2 months ago;
5. That defendant refused to turn over the said property even after demand
to do so is made thus, such possession became illegal;
6. Thereafter, the defendant remained in possession of the property and

deprived the plaintiff of the enjoyment thereof; and
13
THOUSAND PESOS (Php 50,000.00), which the Defendant should also

be held answerable;
8. This action is governed by the Rules on Summary Procedure.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed unto this

Honorable Court that:
(a) After trial, judgment be rendered in favor of herein Plaintiff and ordering
Defendant and all persons claiming right under him to permanently
VACATE the premises in question and give the immediate possession
thereof to the Plaintiff;
(b) Pay plaintiff the amount of FIFTY THOUSAND PESOS (Php50,000.00),

as and by way of attorney’s fees;
(c) Pay plaintiff the cost of this suit.
Plaintiff prays for such other remedies and reliefs as may be deemed just and
equitable under the premises.
May 10, 2012. Quezon City.

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567

I, JUAN AYSION SANTOS, of legal age, after being duly sworn to in

accordance with law, depose and says:
That I am the petitioner in the above-titled case; that I have caused the
preparation of the preparation of the foregoing petition and understood the
contents thereof; and I hereby declare that all the allegations contained therein
are true and correct according to my knowledge and belief.
Furthermore, I hereby certify that I have not filed nor caused to be filed a
similar case involving the same issues in the Supreme Court, Court of Appeals or
any tribunal or agency, I shall inform the Court, tribunal or agency of such fact
within five (5) days thereof.
IN WITNESS WHEREOF, we have hereunto set our hand this 10th day
of May 2012, City of Quezon, Metro Manila, Philippines.
14
JUAN AYSION SANTOS

Plaintiff
CTC No. 1234565
Issued On: March 4, 2012
Issued At: Quezon City
E J E C T M E N T ( UNLAWFUL DETAINER)
ANSWER

QUEZON CITY
Branch 031
JUAN AYSION SANTOS

Plaintiff,

JOHN CHIU CO
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x
ANSWER
DEFENDANT, through the undersigned counsel, and unto this Honorable

Court most respectfully submit this ANSWER for Unlawful Detainer and in
support hereof makes the following assertion:
1. Defendant admits paragraphs 1 and 2 insofar as the personal

circumstances of the plaintiff and defendant are concerned;
2. Defendant specifically denies paragraph 3 of the complaint in as much as

the plaintiff allowed for the extension of the lease contract;
3. Defendant partially admits paragraph 4 and 5 in as much as he refuses to

turn over the said property only because of the extension granted to him
by the plaintiff;
THOUSAND PESOS (Php 50,000.00), which the Plaintiff should also be
held answerable therefore;
5. This action is governed by the Rules on Summary Procedure;
PRAYER
15
WHEREFORE, premises considered, it is respectfully prayed unto this

Honorable Court that:
(d) After trial, judgment be rendered in favor of herein Defendant dismissing

the complaint;
(e) Pay the Defendant the amount of FIFTY THOUSAND PESOS

(Php50,000.00), as and by way of attorney’s fees;
(f) Pay the Defendant the cost of this suit.
Defendant prays for such other remedies and reliefs as may be deemed just
and equitable under the premises.
May 16, 2012. Quezon City.
ATTY. SHU B. SAY

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567

I, JOHN CHIU CO, of legal age, after being duly sworn to in accordance
with law, depose and says:
That I am the Defendant in the above-entitled case; that I have caused the
preparation of the foregoing Answer and understood the contents thereof; and I
hereby declare that all the allegations contained therein are true and correct
according to my knowledge and belief.
Furthermore, I hereby certify that I have not filed nor caused to be filed a
similar case involving the same issues in the Supreme Court, Court of Appeals or
any tribunal or agency, I shall inform the Court, tribunal or agency of such fact
within five (5) days thereof.
IN WITNESS WHEREOF, we have hereunto set our hand this 16th day
of May 2012, City of Quezon, Metro Manila, Philippines.
JOHN CHIU CO
Defendant
CTC No. B-124843
On March 3, 2012
16
REPLY

QUEZON CITY
Branch 031
JUAN AYSION SANTOS,

Plaintiff,

JOHN CHIU CO,

Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
REPLY
COMES NOW Plaintiff through the undersigned counsel and hereby

respectfully states that:
1. In the Defendant’s Answer, the said defendant stated that plaintiff allowed
him to extend the lease of the property in question;
2. Defendant is evidently misleading the court in alleging the claim in as much

as the plaintiff did not extend such lease. Neither is there any evidence of
such extension;
PRAYER
WHEREFORE, Plaintiff respectfully prays that judgment be rendered in his

favor in accordance with the original prayer set forth in the plaintiff’s complaint.

Quezon City
IBP No.A-1234567
PTR No. A-12345567
17
MCLE No. A1234567
POSITION PAPER

QUEZON CITY
Branch 031
JUAN AYSION SANTOS,

Plaintiff,

JOHN CHIU CO,

Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
POSITION PAPER FOR THE PLAINTIFF

this Position Paper in the above entitled case, and alleged that:
THE CASE
The case arose from the expiration of the lease agreement between the
plaintiff and defendant and the latter’s subsequent refusal to vacate the former’s
property. Plaintiff now prays for the ejectment of the defendant and the payment
of damages.
FACTS OF THE CASE

#123 Narra St., Fairville, Quezon City, where they may be serve with court
order and other processes;

processes;
3. Defendant was a lessee of the plaintitff’s property in 129 Fairkes St.,

Fairville, Quezon City;
4. That defendant’s lease expired 2 months ago
18
5. That defendant refuses to turn over the said property even after demand
is made;
be held answerable therefore;
ISSUE
3. Whether defendant should be ejected.
4. Whether plaintiff is entitled to damages.
ARGUMENTS
1. Under the law, where a person unlawfully deprives another of his property
as in this case, an ejectment case may be filed against the usurper.
RESERVATIONS

and proper.
PRAYER
WHEREFORE, plaintiff prays that the relief he prayed for in his

complaint be granted and any such other relief which the court may award to the
plaintiff which is just and equitable under the circumstances.

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567
19
POSITION PAPER

QUEZON CITY
Branch 031
JUAN AYSION SANTOS,

Plaintiff,

JOHN CHIU CO,

Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
POSITION PAPER FOR THE DEFENDANT

this Position Paper in the above entitled case, and alleged that:
THE CASE
The case arose from the complaint filed by the Plaintiff against the
defendant on the alleged expiration of their lease agreement.
FACTS OF THE CASE

#123 Narra St., Fairville, Quezon City, where they may be served with
court order and other processes;

Quezon City where he may be served with summons, order and other
court processes;
3. Defendant was a lessee of the plaintiff’s property in 129 Fairkes St.,

Fairville, Quezon City;
4. That defendant’s lease was extended 2 months ago;
5. That as a consequence of the extension, the Plaintiff allowed the

Defendant to stay for 9 months. However, the Defendant was shocked
20
when a couple of weeks after the extension was made, the Plaintiff is
asking him to vacate the property immediately.
be held answerable therefore;
ISSUE
1. Whether the defendant should be ejected.
2. Whether the plaintiff is entitled to damages.
ARGUMENTS
1. Under the law, where a person unlawfully deprives another of his

property, an ejectment case may be filed against the usurper
RESERVATIONS

and proper.
PRAYER
WHEREFORE, premises considered, it most respectfully prayed this

Honorable Court that the instant Case of Forcible Entry shall be dismissed for
want of basis, either in fact or in law.

Quezon City
IBP No.A-1234567
PTR No. A-12345567
MCLE No. A1234567
21
ARBITRATION / COMPROMISE AGREEMENT

QUEZON CITY
Branch 031
JUAN AYSION SANTOS,

Plaintiff,

JOHN CHIU CO,

Defendant.
X - - - - - - - - - - - - - - - - - - - - - - - - - - -X
COMPROMISE AGREEMENT
THE UNDERSIGNED PARTIES
JUAN AYSION SANTOS,

resident of #123 Narra St., Fairville, Quezon City
AND
JOHN CHIU CO,

resident of #123 Acacia St., Fairville, Quezon City
AGREE as follows:
1. That JOHN CHIU CO shall pay for the rent on the property including
back rentals;
2. The plaintiff shall drop this civil case against the defendant.
IN WITNESS WHEREOF, the Parties hereto have mutually and voluntarily

agreed to the above stipulations, and sign this Agreement, at the
METROPOLITAN TRIAL COURT of Quezon City, Branch 031, on this 16th day of
August, 2012 for the consideration and approval of the Honorable Court.
JUAN AYSION SANTOS JOHN CHIU CO

Plaintiff Defendant
22
Assisted by:
JUSTIN C. BERN JESICA A. ASE

Mediator Mediation-Supervisor/Coordinator
23

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JUDICIAL FORMS (SUMMARY PROCEEDINGS)

EJECTMENT (FORCIBLE ENTRY)

Republic of the Philippines

JUAN AYSION SANTOS

-versus- CIVIL CASE No. Q-12345

PLAINTIFF, through the undersigned counsel, and unto this Honorable

1. Plaintiff JUAN AYSION SANTOS, is residing at #123 Narra St.,

2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville,

3. Plaintiff became owner of a certain parcel of land, through a Deed of Sale

4. The parcel of land, situated in #129 Fairville, Barangay Pangsy, Quezon

(Copy of TCT- 12345 is hereto attached as ANNEX “B”);

5. Herein Defendant, through stealth and strategy, occupied the parcel of

miscellaneous accommodation of its lawyers and other personal expenses

7. This action is governed by the Rules on Summary Procedure;

WHEREFORE, premises considered, it is respectfully prayed of this

(c) Pay the cost of this suit.

May 1, 2011. Quezon City, Metro Manila.

ATTY. PHOEMELA G. CRUZ

VERIFICATION AND CERTIFICATION

I, JUAN AYSION SANTOS, of legal age, after being duly sworn to in

JUAN AYSION SANTOS

SUBSCRIBED AND SWORN to before me, in the City of Quezon, this

ATTY. DAN B. SAN

EJECTMENT (FORCIBLE ENTRY)

Republic of the Philippines

JUAN AYSION SANTOS,

-versus- CIVIL CASE No. Q-12345

COMES NOW THE DEFENDANT JOHN CHIU CO, through the

1. DEFENDANT ADMITS the allegations in paragraph 1 and

2. DEFENDANT specifically DENIES the allegations in paragraph 5

WHEREFORE, the answering defendant, most respectfully pray

1. Dismissing the complaint with costs against the plaintiff; and

City of Quezon, June 01, 2012

ATTY. SHU B. SAY

City of Quezon, June 01, 2012

ATTY. PHOEMELA G. CRUZ

EJECTMENT (FORCIBLE ENTRY)

Republic of the Philippines

JUAN AYSION SANTOS,

-versus- CIVIL CASE No. Q-12345

JOHN CHIU CO,

COMES NOW Plaintiff through the undersigned counsel and hereby

2. Defendant is evidently misleading the court in denying the existence of the

WHEREFORE, Plaintiff respectfully prays that judgment be rendered in his

Quezon City. May 4, 2012

ATTY. PHOEMELA G. CRUZ

PTR No. A-12345567

EJECTMENT (FORCIBLE ENTRY)

Republic of the Philippines

JUAN AYSION SANTOS,

-versus- CIVIL CASE No. Q-12345

JOHN CHIU CO,

POSITION PAPER FOR THE PLAINTIFF

PLAINTIFF, by counsel, unto this Honorable Office, respectfully submits

FACTS OF THE CASE

1. Plaintiff JUAN AYSION SANTOS, is a resident of #123 Narra St., Fairville,

2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville,

3. Plaintiff became owners of a certain parcel of land, through a Deed of Sale

4. The parcel of land is situated in 129 Fairville, Barangay Pangsy, City of

6. That Defendant, despite repeated demand, refused to vacate the land.

1. Whether or not defendant should be ejected.

2. Whether or not plaintiff is entitled to damages.

1. Under the Rules of Court, where a person unlawfully deprives another of