FORM 0098.

– COMPLAINT IN INTERVENTION

(Court)

S. C.,
Plaintiff,
–versus–
E. Q.,
Defendant,
H.C., CIVIL CASE
No._________
Intervenor,

COMPLAINT

H.C. through counsel upon leave to intervene first granted

by the Court, alleges:

1. (Averment of Names and Residences).

2. That herein Intervenor has been, for the last seven
(7) years, and still is, the guardian and caretaker of the
fishpond which is the subject matter of the present action for
accounting between plaintiff and defendant.
3. That it was, and is, the contract between the
Intervenor, on the one hand, and Plaintiff and Defendant as co-
owners of said fishpond, on the other, that the Intervenor
would receive a monthly salary of P80.00, plus, 10% of the
yearly net proceeds of the fishpond, as his compensation as
guardian thereof.
4. That the average yearly net proceeds of the fishpond
amount to P10,000.00, more or less.
5. That for the last seven (7) years, the Intervenor had
not been given even a single centavo corresponding to his 10%
share in said net proceeds.

WHEREFORE, Intervenor prays for judgement:

1. Ordering the payment to him of his share in the
net proceeds of the produce of the fishpond for the last 7 years
at the rate of P1,000.00 per year.
2. (Costs and other reliefs).

(Place, date and signature)