9.

Considering that the defendants are his siblings, plaintiff allowed and
tolerated their continued stay at his property;

10. On February 4, 2016, the plaintiff communicated with the defendants his
intention to utilize the land occupied by the latter for his own use;

11. Unfortunately, the defendants refused to yield to his demand. Worse,

they introduced improvements in the erected structures. The plaintiff also
came to know of the plan of the children of the defendants to construct their
own individual and separate houses on the same lot. Pictures depicting the
structures erected by the defendants are also herein attached and marked as
Annex C;
12. Left with no other recourse, the plaintiff sought the aid of the barangay
officials of Poblacion Norte, Paniqui, Tarlac. Sadly, their personal
confrontation did not result to any settlement. As such, the corresponding
Certificate to File Action was issued; the same is attached and marked as
Annex C;
13. The continued occupation of the defendants over the subject property is
only by the tolerance of the plaintiff, hence after his demand to the former
went unheeded, their occupation over the same became illegal. Accordingly,
the defendants must demolish the structures they have erected and
surrender the occupation and possession over the land in favor of the
plaintiff. The latter, being the registered owner of the property, has the right
to exercise all the attributes of ownership relative to the property;

14.Because of the actions of the defendants, the plaintiff was constrained to

institute the instant case to which he incurred litigation expenses in the
amount of FIVE THOUSAND PESOS (P5,000 00);
15. The defendants should also be made to pay monthly rentals for their use
of the subject property from the time the instant complaint is filed until they
vacate the same, to be computed in the amount of TWO THOUSAND PESOS
(P2,000.00) for each structure:
16. Moreover, as a result of the acts of the defendants in withholding
possession over the property, the plaintiff suffered and continues to suffer
mental anguish and anxiety. Each of the defendants must be held liable for
moral damages in the amount of TWENTY THOUSAND PESOS
(P20,000.00);
17. Because of the unjustified acts and evident bad faith on the part of the
defendants, each of the latter must also be held liable for exemplary damages
in the amount of TWENTY THOUSAND PESOS (P20,000.00);

18. The plaintiff is represented by the Public Attorney's Office is also entitled
to the payment of reasonable attorney's fees in accordance with R.A. 9406;
19. The defendants should also be made to pay the cost of this suit.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that:

1. After due notice and hearing, a judgement be issued, ordering the
defendants to demolish/remove the structures they have erected on
the subject land and immediately vacate and surrender the possession
of the same in favor of the plaintiff;

2. The defendants be ordered to solidarity pay FIVE THOUSAND PESOS

(P5,000.00) to the plaintiff as litigation expenses;

3. The defendants be ordered to pay TWO THOUSAND PESOS

(P2,000.00) per month for each of the erected structure as rentals over
the property, to be reckoned from the filing of the instant complaint
until they vacate the same;