Republic of the Philippines

REGIONAL TRIAL COURT

Sixth Judicial Region
Branch ___
Iloilo City

BEATRICE ALONZO, Plaintiff, Civil Case No. _____

For: Possession of real

-versus- proper

SPOUSES GERALDO ANDERSON

and JULIANA BARETTO,
Defendant.
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COMPLAINT

COMES NOW PLAINTIFF, by the undersigned counsel and to

this Honorable Court, most respectfully states:

1. That plaintiff Beatrice Alonzo is of legal age, Filipino,

single and a resident of Simon Ledesma, Jaro, Iloilo City, Philippines
where they may be served with summons and other court processes;

2. That defendants spouses Juliana and Geraldo Anderson

are of legal age, Filipinos and residents of East Baluarte, Molo, Iloilo
City, Philippines, where they may be served with summons and other
court processes.

3. That Plaintiff is the owner of 143 fighting cocks in the

possession of the defendants.

4. That on December 15, 2018, defendants rented from

plaintiff 143 fighting cocks for a month from December 15, 2018 to
January 15, 2019 for the Philippine Slasher Cup event in the amount
of P100,000.00 to be paid half on December 15, 2018 and the other
half on January 15, 2019.
 A machine copy of the rental agreement is hereto attached as
Annex “A”.

5. That on January 19, 2019 and for the next three (3) days
thereafter, plaintiff demanded from defendants the return of said
fighting cocks and the payment of P50,000 as remaining balance plus
interest; but defendants failed and refused, and continue to fail and
refuse to pay and return the same to plaintiff, repeated demands
notwithstanding.
Copies of the letter of demand are hereto attached as Annexes
“B”, “C” and “D”.

6. That the value of the 143 fighting cocks is P341,000.00.

7. That plaintiff is ready and willing to give bond executed to

the defendants in double the value of the property for the return of the
143 fighting cocks to the defendant should be adjudged, or for the
payment of such sum that defendants may recover from plaintiff in
this action.

8. That the refusal of the defendants to abide with the rental

agreement is a breach of contract and have compelled the plaintiff
to come to court and enforce its rights violated by defendants. Plaintiff
was constrained to engage the legal services of the undersigned
counsel, with whom it agreed to pay the sum of P50,000.00 as as and
for attorney’s fee plus the sum of P2,000.00 per court appearance,
which amount defendants must be ordered to reimburse the plaintiff
in the concept of actual damages.

Copy of the Retainer Agreement is attached hereto as Annex

“E” and made as integral part hereof;

PRAYER
WHEREFORE, PREMISES CONSIDERED, it is most
respectfully prayed of this Honorable Court, that after due notice and
hearing judgment be rendered in favor of the plaintiff and ordering
defendants, jointly and severally:
1. To immediately deliver the 143 fighting cocks illegally
possessed by the defendants to the plaintiff;
2. To order the payment of P50,00.00 as unpaid balance
plus interest thereon at 12% per annum from January 2019 until full
payment is made;
3. To order the payment of the cost of the suit, attorney’s
fees in the amount of P50,000.00, plus appearance fees of counsel,
docket fees paid and other legal and judicial expenses resulting from
this suit as may be proven during trial, all in the concept of actual
damages.
Other reliefs just and equitable in the premises are likewise
prayed for.
Iloilo City, Philippines. October 2, 2019.

CAMILLE ANNE H. CELIZ

Counsel for the Plaintiff
Jaro, Iloilo City
PTR No. 9109968- Iloilo City- March 25, 2019
IBP No. 948149- Iloilo-
Roll of Attorney’s No. 85312
MCLE Comliance No. III- 0051965

VERIFICATION AND CERTIFICATION

I, BEATRICE ALONZO, of legal age, single and with address

at Simon Ledesma, Jaro, Iloilo City, after having been sworn to in
accordance with law hereby depose and say:
1. That I am the plaintiff in the above entitled case;
2. That I have read and caused the preparation of the
foregoing complaint and that all the allegations therein are true and
correct of my personal knowledge or based on authentic records;
3. That I have not filed a similar action or proceeding
involving the same issue before the Supreme Court, Court of Appeals
or any tribunal or quasi-judicial agency; that to the best of my
knowledge, no such action or proceeding is pending therein; and that
if I should thereafter learn that a similar action has been filed or is
pending, I undertake to report such fact within five (5) days therefrom
to this Honorable Court.

BEATRICE ALONZO
Principal

SUBSCRIBED AND SWORN to before me this 2nd day of

October 2019, in the City of Iloilo, Philippines, affiant exhibiting to me
her Philippine Passport with number PP0998995 and valid until
December 31, 2030; that she is the same person who executed and
voluntarily signed the foregoing Verification/ Certification Against
Forum Shopping, and she acknowledged before me that the same is
her free and voluntary act and deed.
 WITNESS MY HAND AND SEAL.

Doc. No. _____; GRETCHEN B. ANG

Page No._____; Notary Public
Book No._____; Notarial Commission No. 91
Series of 2019. UNTIL DEC 31, 2020
PTR No. 3152378- Jan. 5, 2019- Iloilo City
IBP No. 8761234- Jan. 5, 2019- Iloilo City
Roll of Attorneys No. 87654