Republic of the Philippines

Municipal Trial Court in Cities

Imus City, Cavite

JAIRUS LIMBAGAN
Plaintiff,

-versus- CIVIL CASE No. I-12345

For: EJECTMENT (FORCIBLE ENTRY)

JUAN DELA CRUZ

Defendant.
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COMPLAINT

PLAINTIFF, through the undersigned counsel, and unto this Honorable Court
most respectfully submits this Complaint for Forcible Entry and in support hereof
makes the following assertions:

1. Plaintiff JAIRUS LIMBAGAN, is residing at #321 Ilang Ilang St., Unfairville,

Imus City, Cavite, where he may be served with court order and other processes;

2. Defendant JUAN DELA CRUZ is a resident of #567 Ipil St., Lucas Ville, Imus
City, Cavite where he may be served with summons, order and other court
processes;

3. Plaintiff became owner 0f a certain parcel of land, through a Deed of Sale from
the original owner, LINDSAY DE LEON (A copy of the Deed of Sale is hereto
attached as Annex “A”);

4. The parcel of land, situated in #556 Kawayan St., Unfairville, Imus City, Cavite, is
covered by Transfer of Certificate of Title No. 12345 issued by the Register of
Deeds of Quezon City and is more particularly described, as follows:

(Description)

(Copy of TCT- 12345 is hereto attached as ANNEX “B”);

5. Herein Defendant, through stealth and strategy, occupied the parcel of land in
question and refuses to vacate the same despite repeated oral and written
demands. (Copy of the written demand is hereto attached as Annex “C”);
 6. The same acts of the Defendant compelled the Plaintiff to incur damages
consisting of attorney’s fees in the amount of Twenty Five thousand pesos
(P25,000.00) pesos and filing fee, cost of transportation and other miscellaneous
accommodation of its lawyers and other personal expenses to be incurred in
attending the hearings of this case in the amount of EIGHTY THOUSAND
PESOS (Php 80,000.00).

7. This action is governed by the Rules on Summary Procedure;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable

Court that, after the proceedings, judgment be rendered in favor of the Plaintiff and
ordering the Defendant and all persons claiming rights under him to:

(a) Permanently VACATE the premises in question and give the immediate right of
possession to the Plaintiff;

(b) Pay plaintiff the amount of Twenty Five Thousand Pesos (P25,000.00) by way of
attorneys fees and Eighty Thousand Pesos (P80,000.00), by way of other
litigation expenses; and,

(c) Pay the cost of this suit.

Plaintiff prays for such other remedies and reliefs as may be deemed just and
equitable under the premises.

September 19, 2020. Imus City, Cavite.

ATTY. AMBROSIO J PUNONGBAYAN

Counsel for Plaintiff
Imus City, Cavite
Roll of Attorneys No. 5678918
IBP No. A-2468923
PTR No. A- 5487996
MCLE No. A-2299963