EXERCISE NO.

3
COMPLAINT
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2. That the plaintiff has been the legal, actual and physical possessor of a
parcel of land, consisting of one-sixth (1/6) share together with the
improvements, being a portion, of Lot No. 3463 of the Dumaguete
Cadastre, described and bounded as follows:
ORIGINAL CERTIFICATE OF TITLE
No. 567-A (now TCT No. T-81)

3. A parcel of land in Barrio Candaw-ay, Dumaguete City, Philippines.

Bounded on the NE., by Lots Nos. 3462 & 3466; on the SE., by Lot. No.
3466, Sapang Okay, and Lot No. 3463; on the SW., by Lots Nos. 3463 &
3464; and on the NW., by Lots 3461 and 3458; containing an area of FORTY
FIVE THOUSAND FIVE HUNDRED SIXTY EIGHT (45,568) SQUARE METERS
and assessed at P150.00 under Tax Declaration No. 15308.
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5. That from 1925, plaintiff took actual and physical possession of the
premises in question until 1961, when in May 1961 and September 8, 1961,
his possession has been disturbed by defendant and dispossessed plaintiff
by force, intimidation, threat, strategy, to the prejudice of plaintiff.
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12. That in May 1961, defendant entered the land in question, gathered the
coconuts on the land and availed herself of the proceeds in the amount of
P49.00.
13. That despite the pleading by plaintiff not to repeat her unlawful act
alleged in the preceding paragraph, which lasted one day, the defendant
again entered the land in question on September 8, 1961.
14. That plaintiff fears that since harvest time is approaching, defendant will
again enter the land and harvest the products.
 PETITION FOR PRELIMINARY INJUNCTION
15. Paragraphs 1 to 14 are reproduced herein by reference.
16. That the unlawful acts of the defendant would cause great injury to
plaintiff.
17. That plaintiff is entitled to an injunction against the acts of defendant.
18. That plaintiff is willing to put up the requisite bond for the issuance of
the injunction.