Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
QUEZON CITY
Branch 31

JUAN AYSION SANTOS

Plaintiff,

-versus- CIVIL CASE No. 16-12345

For: EJECTMENT (FORCIBLE ENTRY)

JOHN CHIU CO
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - - - -x

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 JUAN AYSION SANTOS, is residing at #123 Narra St., Fairville,

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

2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville, Quezon

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

3. Plaintiff became owner of a certain parcel of land, through a Deed of Sale from
the original owner, JANICE DY LEE. (A copy of the Deed of Sale is hereto
attached as Annex “A”);

4. The parcel of land, situated in #129 Fairville, Barangay Pangsy, Quezon City, 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 Thirty thousand pesos (P30,000.00)
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 FIFTY THOUSAND PESOS
(Php 50,000.00).

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 Thirty Thousand Pesos (P30,000.00) by way of
attorney’s fees and Fifty Thousand Pesos (P50,000.00), 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.

May 1, 2016. Quezon City, Metro Manila.

ATTY. MARIANNE ENDRIANO

Counsel for Plaintiff
Quezon City
Roll of Attorneys No. 1234567
IBP No. A-1234567
PTR No. A- 1234567
MCLE No. A-1234567

ATTY. RE CHARLES TUPAS

Counsel for Plaintiff
Quezon City
Roll of Attorneys No. 1234568
IBP No. A-1234568
PTR No. A- 1234568
MCLE No. A-1234568

ATTY. MARY ANNE CAÑETE

Counsel for Plaintiff
Quezon City
Roll of Attorneys No. 1234569
IBP No. A-1234569
PTR No. A- 1234569
MCLE No. A-1234569

ATTY. MARY JO DECOLONGON

Counsel for Plaintiff
Quezon City
Roll of Attorneys No. 1234570
IBP No. A-1234570
PTR No. A- 1234570
MCLE No. A-1234570
 VERIFICATION AND CERTIFICATION
AGAINST NON- FORUM SHOPPING

I, JUAN AYSION SANTOS, of legal age, after being duly sworn to in

accordance with law, depose and attest:

That I am the petitioner in the above-titled case; that I have caused the preparation
of the foregoing petition and understood the contents thereof, and I hereby declare that all
the allegations contained therein are true and correct according to my knowledge and
belief.

Furthermore, I hereby certify that I have not filed nor caused to be filed any other
similar case involving the same issues in the Supreme Court, Court of Appeals or any
other tribunal or agency and that, should there be any other such case/s that may have
been filed, I hereby bind myself to inform the Court of such fact within five (5) days
from the discovery thereof.

IN WITNESS WHEREOF, I have hereunto set our hand this 1st day of May
2016, City of Quezon, Metro Manila, Philippines.

JUAN AYSION SANTOS

Affiant
CTC No. 1234565
Issued On: October 4, 2015
Issued At: Quezon City

SUBSCRIBED AND SWORN to before me, in the City of Quezon, this 1st day
of May 2016, City of Quezon, Metro Manila, Philippines, affiant having ex habited to me
his Drivers License No. F01-200215674, issued at Quezon City, Philippines.

ATTY. DAN B. SAN

Notary Public
Until December 31, 2017
PTR No. A-123056
Issued at Quezon City
On January 1, 2015

Doc. No. 180;

Page No. 35;
Book No. 2;
Series 2016.