Professional Documents
Culture Documents
Jigs Castillo,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Unlawful Detainer
Roan Gallos,
Defendant.
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COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1. That the plaintiff, KRUL ACOSTA, is of legal age, Filipino citizen, single, with
residence and postal address at 123 Benitez Street, Manila;
2. That the defendant, MEGAN VITUG, is of legal age, Filipino citizen, single, with
residence and postal address at 456 Modesto Street, Manila, where they may be
served with summons and other court processes;
3. The plaintiff is the owner of a land over which an apartment had been
constructed located 654 San Pedro Street, Manila;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant the
aforesaid apartment for a consideration of P5,000.00 a month as rental to be
paid within the first ten (10) days of each month starting November 3, 2011;
5. The defendant failed to pay the agreed rental for several months starting
February 19, 2012 up to the present;
6. On May 3, 2012, the plaintiff sent a letter of demand to vacate the apartment
which was received by the defendant as shown in the registry return receipt
hereto attached as Annex “A”;
7. Despite said letter of demand which was repeated by oral demands, the
defendant failed and still refused to pay the agreed amount of rentals and to
vacated the apartment;
8. By reason of failure of the defendant to vacate the premises and to pay the
unpaid rentals, the plaintiff was compelled to file this complaint engaging the
services of counsel in the amount of P10,000.00.
WHEREFORE, premises considered, it is most respectfully prayed unto this
Honorable Court that, after hearing, judgment be rendered ordering the defendant:
By:
ABCEDEE REYES
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila
REPUBLIC OF THE PHILIPPINES
METROPOLITAN TRIAL COURT
City of Manila
Branch 1
Jigs Castillo,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Forcible Entry
Roan Gallos,
Defendant.
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COMPLAINT
PLAINTIFFS by counsel, to this Honorable Court respectfully avers that,
1. Plaintiff Jigs Castillo, of legal age, Filipino and residents of Suns Condominium,
Quezon City.
2. Defendant Roan Gallos, Filipino is residents of Moon Condominium Quezon City,
where they may be served summons and other processes.
3. The plaintiff is the owner of a parcel of land located in San Mateo, Isabela,
containing an area of 300 SQUARE METERS, more or less which realty is titled
in the name as evidence by Transfer Certificate of title No. T-12345 of the
Registry of Deeds of Quezon City, photocopy of TCT No. T-12345 is hereto
attached and made an integral part of Annex “A”.
4. Plaintiff, by themselves and through their predecessors in-interest, have been in
peaceful possession of the land continuously and uninterrupted for more than
fifty (50) years;
5. On January 28, 2019, defendant together with hired laborers without the
knowledge, consent and authority of the plaintiff, by force, strategy and stealth
entered the land described in paragraph 3, encroached on and took possession
of a portion of the land having an area of 500,000 square meters with the
following bounderies: on the Northeast by the remaining portion; and on the
Southwest by a provincial Road.
6. Simultaneous to their unlawful entry, defendant started construction of a
residential house notwithstanding repeated demands for them to stop and to
desist from further acts of dispossession.
7. Plaintiff, by themselves and through their representative, repeatedly demanded
of the defendant to vacate the area occupied by them and to deliver the peaceful
possession of the same to them, but defendants, without any just or legal reason,
refused and continue to refuse to leave the premises and restore peaceful
possession to the plaintiffs of the portion which they unlawfully wrested from the
plaintiff.
8. Efforts for a possible settlement and/or reconciliation was exerted by the plaintiff.
certification issued by Barangay Secretary Levy teodorao dated feb. 9, 2011 is
hereto appended and marked as Annex “B”.
9. As a consequence of the unlawful entry and occupation of their land by the
defendant and their subsequent refusal to vacate the premises, plaintiff was
compelled to file this action and, for this reason have to engage the services of
counsel for an agreed professional fee of P25000.00
10. As further consequence of the defendant refusal to surrender and restore
peaceful possession of the land, plaintiff, suffered mental anguish, emotional
disturbance, embarrassment besmirched reputation which entitles them to
recover moral and exemplary damages amounting to not less than P50,000.00
PRAYER
WHEREFORE, plaintiff respectfully prays the Honorable Court to render
judgment;
1. Ordering the defendant to vacate the premises of the area occupied by them and
to deliver peaceful possession of the same to the plaintiff or their representative
2. Ordering the defendant to remove any and structure which they, in bad faith,
have erected in the area occupied by them or, in default thereof, to order the
demolition of their building or structures which are standing in the land, all at the
expense of the defendants.
3. Condemning the defendant to pay to the plaintiff.
a. The sum of P25,000.00 as attorney’s fees and the sum of P5,000 as
expense of litigation;
b. Moral and exemplary damage of not less than P50,000.00; and
c. The costs of this suit:
d. Plaintiff pray for other reliefs and remedies as may be just and equitable in
the premises.
Quezon City, March 10, 2019
GREETINGS!
Mortgagee Simon Contapay, of legal age, Filipino, single , and a resident of 1234 Suns
Condominium Quezon City Philippines, most respectfully alleges:
4.That under the terms and condition of the Contract, the Mortgagee is entitled to
foreclose extra-judicially the mortgaged property, which is more particularly described
as follows:
Land located in Tinago Quezon City, containing an area of 300 SQUARE METERS,
more or less which realty is titled in the name as evidence by Transfer Certificate of title
No. T-12345 of the Registry of Deeds of Quezon City.
PETITION
1. Petitioner is the mother of the minor Aveline Olives who was born out of the valid
marriage between petitioner and respondent Lanz Aidan L. Olives;
2. The petitioner and respondent have been separated de facto since 2019;
3. The minor has been living with the petitioner in the house of the latter’s mother
and the minor’s maternal grandmother since the petitioner and the respondent
separated;
5. Being below seven (7) years of age, custody of the minor is naturally presumed
to belong to the petitioner, as her mother. Consequently, respondent’s refusal to
allow petitioner to regain custody over the minor is unlawful and unjustified.
WHEREFORE, petitioner respectfully prays that a Writ of Habeas Corpus be issued
directing respondent to make a return showing his legal authority to detain the minor
child, subject of this petition, and thereafter, present the minor child personally before
the Court on a date and time it chooses.
To sell, offer for sale, and come to an agreement as to the purchase price and
thereafter to sign for us and in our name and receive payment from the sale of our
property more particularly described as follows:
1. To sell, assign and dispose of a parcel of land covered by TCT No. 123456, situated
at Block 2 Lot 3 Palmera Homes Novaliches, including the improvements thereon under
such terms and conditions acceptable to my Attorney-in-Fact;
2. To sign, execute and deliver the necessary Deed of Sale covering such sale including
any and all documents that may be necessary or required thereto and to deliver
possession of the property to said vendee;
3. To receive the proceeds of the sale, either in cash or in check and to pay expenses
for capital gains, real property tax and any and all such expenses that may be agreed
upon between the vendee;
4. To do such any other act or thing that may be required necessary or incidental to
carry out effectively any and all of the purposes for which this authority is hereby given;
Doc. No.______;
Page No. ______;
Book No.______;
Series of 20___.
REPUBLIC OF THE PHILIPPINES
METROPOLITAN TRIAL COURT
City of Quezon City
Branch 1
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INFORMATION
The undersigned, Jigs Castillo, accuses Roan Gallos, of the crime of THEFT, committed
as follows, to wit:
PROSECUTOR
Witnesses:
____________________
____________________
Republic of the Philippines
National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 147
Makati City
People of the Philippines
Plaintiff,
Vs
Jigs Castillo,
Accused
PETITION FOR BAIL
Accused, through the undersigned counsel, unto this Honorable Court, respectfully
states:
1. That accused is currently detained at the Makati City Jail for the charge of Frustrated
Murder and has been behind bars since his arrest on August 1, 2019;
2. That no bail has been recommended for his temporary release on the assumption that
the evidence of guilt is strong;
3. That the prosecution's evidence of guilt against accused, however, is weak as there is no
direct evidence that will point to the accused to have committed the the charges against
him. The records will show that accused was malicious implicated in the case through
the sworn statements of SINUNGALING and BULA AN who subsequently recanted their
testimonies and confessed, among others, that they were made to sign the "affidavits of
witnesses" against their will. (copies of the Affidavits of Recantation are hereto attached
as Annexes "A" and "B")
4. That there is no other physical or documentary evidence to show that accused is guilty of
the crime charged.;
5. That the burden of showing that evidence of guilt is strong is on the prosecution, and
since this fact is not satisfactorily shown, accused is entitled to bail as a matter of right
during the pendency of the criminal case.
WHEREFORE, upon prior notice and hearing, it is respectfully prayed of this
Honorable Court that accused AKU SADO be allowed to post bail for his
temporary liberty pending trial of the criminal charge against him.
Other just and equitable reliefs are likewise prayed for.
Respectfully submitted.
15 August 2020
City of Makati.
I, KRUL ACOSTA, of legal age, Filipino citizen, single and resident of 123 Benitez
Street, Manila, after having been duly sworn to in accord Nance with law do hereby
depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and have read the
allegations contained therein;
3. The allegations in the said complaint are true and correct of my own knowledge
and authentic records;
4. I hereby certify that I have not commenced any other action or proceeding
involving the same issues in any court, tribunal or quasi-judicial agency and, to
the best of my knowledge, no such other action or claim is pending therein;
5. That if I should learn thereafter that a similar action or proceeding has been filed
or is pending, I hereby undertake to report that fact within five (5) days therefrom
to the court or agency where the original pleading and sworn certification
contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the foregoing facts
and to comply with the provisions of Adm. Circular No. 04-94 of the Honorable
Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 24th of
September 2012, in the City of Manila.
JIGS CASTILLO
Jigs Castillo,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Forcible Entry
Roan Gallos,
Defendant.
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MOTION FOR APPROVAL OF
COMPROMISE AGREEMENT
The parties agree that the approval of this agreement by the Court shall put an end
to this litigation, except for purposes of execution in case of default.
COMES NOW the Intervenor, by the undersigned counsel, and unto this Honorable
Court, most respectfully requests for leave to intervene in the above-captioned
case, for the following reasons:
That the Intervenor has a legal interest in the matter in litigation, or in the success of the
complainant, or is so situated as to be adversely affected by a distribution or other
disposition of the parcel of land, subject matter of the above-captioned case;
PRAYER
From August 3 to December 2019, defendant never paid anything to herein plaintiff.
The check that he issued as partial payment for the first month also bounced.
2.The said allegation is not averred with sufficient definiteness and particularity,
specifically it does not mention the amount of the check therein mentioned,
its check number, date, and the drawee bank;
4.However, due to the fact that defendant corporation had to transfer its liaison offices
depending on its project sites, the check stub where the above-mentioned check came
from was probably misplaced and could no longer be found;
PRAYER
WHEREFORE, defendant most respectfully prays that an order be issued by this
Honorable Court requiring the plaintiff to make more definite statement as to the
particulars of the check mentioned in paragraph 5 of his complaint, particularly stating
its amount, check number, date, and the name of the drawee bank.
Quezon City, Philippines, December 19 2020.
ELLA CORPUZ MAPA,
Defendant.
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1. On May 5, 2013, plaintiff sued defendant for a sum of money in the amount of
Two Hundred Thousand Pesos (P200,000.00);
2. In his Answer, defendant admitted the obligation and merely stated that he was asking to
be given an extension of time to pay his obligation but that plaintiff instead filed the
Complaint;
3. Said Answer has not tendered any issue and in fact it can be read therefrom that
defendant admitted the obligation; consequently, a judgment on the pleadings may be
rendered.
ELLA CORPUZ MAPA,
Defendant.
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Defendant (or plaintiff), by his undersigned attorney, respectfully moves that the
decision of this Honorable Court dated June 10, 2020 and received on June 27, 2020
be set aside and new trial be granted on the following grounds:
GROUNDS
ARGUMENTS
That on July 11, 2020 a receipt was issued by the ABC Inc. which will certainly show
that an agreement between the parties herein are entered into.
LIELA PADILLA CORPUZ,
Defendant.
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COMES NOW, the Plaintiff through undersigned counsel and to this Honorable
Court respectfully alleged:
3. That up to the present, the defendant had not filed any motion for reconsideration or had
appealed from said decision, hence the decision has become final and executory.
Petitioners, thru counsel, unto this Honorable Court most respectfully state:
1. That petitioners are Roan Gallos Castillo and Jigs Castillo, Filipino Citizens,
both of legal age, spouses and with residence at 1234 Suns Condominium
Quezon City, where they may be served with the processes of this Honorable
Court;
2. That the petitioners were married on January 19 2020 at Quezon City, this
fact is evidenced by their “Certificate of Marriage”.
3. That the herein petitioners desire to adopt Simon Contapay, born ON July 20
2017 a copy of the “Certificate of Live Birth” of minor Simon Contapay.
4. That petitioner Jigs Castillo gives his consent to the adoption of the subject
minor. This fact is evidenced by the “Affidavit of Consent” of petitioner Jigs
Castllo.
5. That the subject minor hereby gives her consent to the adoption and the legal
implications of the adoption were explained to her.
6. That the subject minor has no real properties except for some personal
effects;
7. That the subject minor is physically fit to be adopted by the petitioners. This
fact is evidenced by the medical certificate.
8. That the subject minor possesses all the qualifications and none of the
disqualifications for her to be adopted by the herein petitioners;
9. That the herein petitioners possess all the qualifications and none of the
disqualifications to adopt the subject minor;
10. That the herein petitioners are in possession of full civil capacity and legal
rights to adopt the subject minor;
11. That the petitioners have not been convicted of any crime involving moral
turpitude.
13. That prior to the filing of the instant petition, a social worker has been
assigned to the subject adoption and he has prepared the Child and Home
Study Report.
14. This petition will serve the best interest and well-being of the subject minor.
PRAYER
WHEREFORE, petitioners pray that after due notice, publication, and hearing,
this petition for adoption be granted and:
b. That the last name of Contapay be changed to Castillo, which is the surname of
the petitioners.
This affidavit, is being offered to allow the affiant to adopt the minor Simon
Contapay.
Q1: Please state your name and other personal circumstances for the record.
A1: I am Roan Gallos, 29 years old, married, and resident of ___.
Q2: Are you willing to adopt the minor and give him the proper care and support of a
parent
A2: Yes, Sir.
Q3: Are you willing to abide rules and laws and to follow the obligations under the
domestic adoption law
A3: Yes, Sir.
Q4: Do you have any other children?
A4: None, Sir.
Roan Gallos
Affiant