Republic of the Philippines

MUNICIPAL TIRAL COURT IN CITIES

11th Judicial Region
Tagum City, Davao del Norte

------------------------------------------, Civil Case No.________________

Plaintiffs,
FOR: FORCIBLE ENTRY, DAMAGES and
-versus- ATTORNEY’S FEES

____________________________
Defendants.
X--------------------------/
MOTION FOR STATUS QUO ANTE ORDER

COME NOW, plaintiffs, assisted by counsel, to this Honorable Court, most

respectfully states:

1. That sometime on June 2020, defendants through stealth, fraud and

intimidation illegally cut down plaintiffs’ coconut trees and constructed a
cement fence on plaintiffs’ properties which is the subject of the case herein;

2. That sometime on October 2020, defendants have started to illegally destroy

and dismantle plaintiff’s two-storey house made of strong wood materials
constructed on Lot _______________, which is one of the subject properties
in the case herein;

Attached herein as Annex “A” is the Blotter Report from PNP

____________and Annexes “__” to “__” are the picture of the destroyed
houses and continuing construction works in the subject properties.

3. That defendants have a clear and unmistakeable right to the subject property
since they are the prior possessors of the same before defendants illegally
entered the same and excluded plaintiffs’ therefrom;

4. That the acts of defendants in destroying plaintiff’s house and continuing the
construction works therein within the land subject of litigation is a clear
violation of preserving the status quo of the land while the herein case is
pending before this Honorable Court;

5. That the defendants acts of destroying plaintiffs’ houses on the subject

property and continuing construction works will make the eventual resolution
of this case before this Honorable Court will be rendered useless and pre-
emptive of the final decision of the same;

1
 6. That defendants have been aware that a Complaint has been filed against
them regarding the subject properties as evidenced by their Answer dated
__________________ and despite this awareness, they have continued their
illegal acts on the lands subject of litigation which is a clear mockery of the
judicial proceedings before the Honorable Court.

PRAYER

WHEREFORE, with the foregoing premises considered, it is respectfully prayed to

this Honorable Court that the instant motion be GRANTED and a STATUS QUO ORDER
be issued against defendants to stop their construction works and preserve the existing
improvements introduced by plaintiffs on the properties subject of litigation herein.

Other relief and remedies deemed just and equitable under the premises are
likewise prayed for.

____________________, Philippines, _______________, 2020.

_____________________________
Counsel for Plaintiffs
Roll No.____________
PTR No. ___________
IBP OR No. _____________
Address
Tel. No. ____________