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Republic of The Philippines Ninth Judicial Region Branch - Zamboanga City
Republic of The Philippines Ninth Judicial Region Branch - Zamboanga City
- versus – - For -
COMPLAINT
Subdivision, Putik, Zamboanga City; while Plaintiffs PABLO BAZAN, JR. and
HERMIE BAZAN are likewise of legal age, Filipino citizens, and residents of
and INOCENCIA MANUEL are also all of legal age, Filipino citizens, and
LINDA TAUNG are likewise of legal age, Filipino citizens and residents of
JOE and ROSIE G. LACASTESANTOS are of legal age, Filipino citizens and
WILLIAM and SOLITA are also of legal age, Filipino citizens and residents of
Pilar St., Zone IV, Zamboanga City, where they may all be served with
MANUEL BAZAN and SUSANA DE LOS SANTOS, who were among the
described as follows:
while his wife and Plaintiffs’ grandmother SUSANA DE LOS SANTOS died on
indicated in the aforesaid title are the brothers and sisters of MANUEL
described parcel of land died, his share was inherited by his children, who
settlement of his estate, namely, TCT No. 4926 of the Registry of Deeds of
Zamboanga City. Thus, the registered owners then appearing in said title
were as follows:
2792 was issued in favor only of EUGENIO B. MAS, without the other
in-interest, Manuel Bazan, who owned 1/20 shares thereof. Machine copy of
TCT No. T-206,947 – JULPI J. TAUNG, married Linda Taung, 1,342 sq.
meters;
sq. meters.
9. In all these transfers, the 1/20 shares of the plaintiffs which they
10. Having been deprived of their shares in the subject lot, Plaintiffs
filed a complaint against herein Defendants with the Office of the Lupong
located so that they can recover ownership and possession of the 1/20 share
11. The total market value of the property per Tax Declaration Nos.
12. Plaintiffs’ claim over the subject parcels of land constitutes only
13. Due to the erroneous and illegal transfer of the 1/20 shares
which said Defendants should be jointly and severally held liable to Plaintiffs
damages.
possession the 1/20 undivided share of the Plaintiffs over the subject
said share of the subject property. Defendants must turn over possession and
15. To protect the rights and interest of the Plaintiffs in the erroneous
and illegal transfer of their 1/20 share over the subject property to the
Defendants, they were compelled to engage the services of counsel for which
entitling them to recover the same jointly and severally from herein
Defendants.
PRAYE R
undivided share over the subject property with a total market value of
legal expenses.
Plaintiffs prays for such other reliefs as may be just and equitable in
the premises.
VERIFICATION/CERTIFICATION
the Supreme Court, the Court of Appeals or different divisions thereof; or any
other tribunal, or agency; and that if I should thereafter learn that similar
action or proceeding has been filed or is pending before the Supreme Court,
the Court of Appeals or any tribunal or agency, I shall undertake to promptly
inform aforesaid courts and such other tribunal or agency of that fact five (5)
days from the notice.
MANUEL BAZAN
Affiant
NOTARY PUBLIC