REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
MUNTINLUPA CITY

SPOUSES NINO PRESCO and

JACKIE PRESCO,
Plaintiffs,
-versus- CIVIL CASE No. 0123456
For: Accion Reivindicatoria
RANI VILLADOLID,
Defendant.

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COMPLAINT

COMES NOW, Plaintiffs, through the undersigned counsel and unto

this Honorable Court, most respectfully states that:

1. Plaintiffs Nino Presco and Jackie Presco are spouses, both of legal
age Filipino, and currently residing at Lot 12, Block 6, Hukom Street,
Justice Village, Poblacion, Muntinlupa City where they may be served
with summonses, orders, and other court processes;

2. Defendant Rani Villadolid is of legal age, Filipino, and currently

residing at Lot 2, Block 2, Hukom Street, Justice Village, Poblacion,
Muntinlupa City;

3. On 17 June 2014, spouses Presco acquired the 500 sq. m. lot (Lot 1)
through a Deed of Absolute Sale from a certain Ruby Ryza Mae Lee
Kum Kee as shown in ANNEX A;

4. The said parcel of land was covered by TCT No. T-12345 as shown
in ANNEX B. In which has a market value of Php 1, 250, 000.00 and
an assessed value of Php 750, 000.00 as shown in ANNEX C;

5. On 1 July 2019, a relocation survey was conducted by Engr. Princesa

Cacapit over said lot as shown in ANNEX D. The relocation revealed
that Lot 2 has encroached Lot 1 by 2.88 m resulting to an overlap of 36
sq. m. existing since 2012;

6. The said encroachment of Lot 2 is apparent because a portion of the

building and concrete fence was built beyond the property line. Lot 2 which
is covered by TCT No. T-67890 as shown in ANNEX E, is owned and
registered to defendant Rani Villadolid as evidenced by the
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