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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


11th JUDICIAL REGION
Branch 10
Davao City

LAGUNA LOIRE, Civil Case No. 213211


Plaintiff,

-versus-

DAN SCHNEIDER,
Defendant
Third Party Plaintiff,.

-versus-

MAMA SANG,
Third-Party Defendant.

x------------------x

THIRD PARTY COMPLAINT

COMES NOW the Third-Party Plaintiff, DAN SCHNEIDER, by and


through his undersigned counsel and pursuant to Rule 6, Sec. 11 of Rules of
Court, hereby impleads the Third-Party Defendant, MAMA SANG and
alleges as follows:

1. LAGUNA LOIRE, Plaintiff filed a complaint against DAN


SCHNEIDER, Defendant and Third Party Plaintiff.

2. LAGUNA LOIRE alleges that the SALE of a parcel of land covered by


TCT No. T-14344 with DAN SCHNEIDER caused damage to him.

3. DAN SCHNEIDER, in GOOD FAITH, bought the parcel of land


covered by TCT No. T-14344 from MAMA SANG.

4. DAN SCHNEIDER, in GOOD FAITH considering that the SALE


between DAN SCHNEIDER and MAMA SANG is free from any
impediment, sold the parcel of land covered by TCT No. T-14344 to
LAGUNA LOIRE.
5. The parcel of land covered by TCT No. T-14344 was foreclosed by the
Land Bank of the Philippines for the reason that it was mortgaged by
IRANA, co- owner of the parcel of land covered by TCT No. T-14344.

6. If LAGUNA LOIRE recovers against DAN SCHNEIDER any


judgment for their damages then DAN SCHNEIDER is entitled to
judgment against MAMA SANG for all such sums since the SALE of
the parcel of land covered by TCT No. T-14344 was the sole cause of
LAGUNA LOIRE’s damages and injuries.

WHEREFORE, it is respectfully prayed that DAN SCHNEIDER,


Defendant and Third Party Plaintiff, can demand judgment against MAMA
SANG, Third Party Defendant, for all sums that may be adjudged against
DAN SCHNEIDER, as Defendant, in favor of LAGUNA LOIRE, as Plaintiff,
together with all costs incidental to the defense of the principal suit.

Davao City, Philippines, March 5, 2019.

MONKEY LAW FIRM


531, Awesome Building
Bajada, Davao City

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