REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11th JUDICIAL REGION
BRANCH XVI

James Bond,
Plaintiff,

- versus - Civil Case No. 622278

For: Recovery of Possession with
Prayer for issuance of Writ of
Preliminary Injunction and/or
Temporary Restraining Order.
Suka Rap,
Defendant.
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COMPLAINT

Plaintiff thru counsel, and unto this Honorable Court, respectfully

avers that:

1. Plaintiff, James Bond, is of legal age, Filipino Citizen, single, with

residence and postal address at 787 Manga St. Sasa, Davao City;
2. Defendant, Suka Rap, is of legal age, Filipino Citizen, single, with
residence and postal address at Block 34 Hillside NHA, Davao City,
where he may be served with summons and other court processes;
3. Plaintiff is the true and registered owner of a certain parcel of land
situated in Calinan, Davao City, consisting of THREE HUNDRED
(200) square meters, and identified as lot 123-B and covered by the
Transfer Certificate of Title No. 23562356 of the Registry of Deeds of
Davao; Machine copy of the said Transfer Certificate of Title No.
23456 is hereto attached as Annex “A”;
4. Sometime in September 4, 2016, Defendant and his family began to
be in possession of the said property, not by virtue of a title or
contract, but merely upon the Plaintiff’s tolerance, as he had no
immediate need of the said property at that time;
5. The defendant is doing, threatening, or is about to do, or is procuring
or suffering to be done, some acts probably in violation of the
Plaintiff’s rights respecting the subject of the action and tending to
render the judgment ineffectual;
6. The plaintiff hereby applies for writ of preliminary injunction to
restrain the defendant from the act herein complained of, and for this
 purpose hereby offers a bond in such sum as this Honorable Court
may fix.

PRAYER

WHEREFORE, it is respectfully prayed that, after due notice and

hearing, a preliminary injunction be issued forthwith to restrain defendant
from doing the act herein complained of; namely to vacate the property; and
that after trial, said injunction be made permanent, with cost, and with such
further orders that are just and equitable in the premises.

Davao City, February 12, 2020.

ADRIAN PAJARO
Counsel for Plaintiff
Until December 31, 2021
Attorney’s Roll No. 10772
PTR No. 7862245 B; 01-02-20; Davao City
IBP O.R. No. 024454; 01-02-20; Davao
City

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF DAVAO DEL SUR) S.S
IN THE CITY OF DAVAO………..)
X…………………………………….X

VERIFICATION AND CERTIFICATION

I, James Bond, of legal age, after having been duly sworn in accordance
with law, depose and state that:
1. I am a petitioner in the above-stated case representing the republic
of the Philippines;
2. I caused the preparation of the foregoing petition;
 3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and/or on the basis true and
authentic records.
4. I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has
been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signatures this 2 nd

day of February 2019, at Davao City, Philippines.

                            
JAMES BOND
Affiant

SUBSCRIBED AND SWORN to before me in the City of Davao this

th
30 day of April 2016, by JAMES BOND, who has satisfactorily proven
her identity to me through his Voter’s ID issued by the PRC bearing his
photograph and signature and with VIN 1123-12323232-4, that he is the
same person who personally signed the foregoing document before me and
acknowledged that he executed the same.

WITNESS MY HAND AND SEAL this 2nd day of February 2020

in Davao City, Philippines.
 NOTARY PUBLIC
Doc. No. 60;
Page No. 12;
Book No. 01;
Series of 2020.