Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
QUEZON CITY
Branch 31

GENUINE WISDOM I. CRUZ

Plaintiff,

-versus- CIVIL CASE No. 17-3526

For: Ejection (Forcible Entry)

HEATHER FAITH I. SANTOS

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 GENUINE WISDOM I. CRUZ, is residing at #06 Jose Abad Santos Street,
Tacurong city, where she may be served with court orders and other processes.

2. Defendant HEATHER FAITH I. SANTOS, is residing at #07 Gotamco st. Barangay 17,
Pasay city, where she may be served with court orders and other processes.

3. Plaintiff became an owner of a parcel of land , through a Deed of Absolute Sale from
the original owner, SHYNEE A. REYES . A copy of the Deed of sale hereto is attached as
Annex “A”.

4. The parcel of land situated in 605 Tarushi Residence, Barangay 18, Quezon city is
covered by Transfer of Certificate of Title No. 171717 issued by the Registry of Deeds of
Quezon city and is more particularly described as follows:

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 hereto is attached as Annex “B”)

6. The same act of the defendant compelled the Plaintiff to incur damages consisting of
Attorney’s fees in the amount to thirty thousand pesos Ph30,000.00 and filing fee, cost
of transportation and other miscellaneous accommodation of its lawyers and other
personal expenses to be incurred in attending the hearing of the case amounting to Fifty
thousand pesos (Php 50,000.00)

7. This action is governed by the Rules of 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 the
persons claiming right 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 (Php 30,000.00), by way of Attorney’s
Fees, and Fifty Thousand Pesos (Php50,000.00), by way of other litigation expenses;
and,
(c) Pay the cost of the suit.

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

November 5, 2020, Quezon City, Metro Manila.

ATTY. MICHELLE JOY M. ITABLE, CPA

Counsel for Plaintiff
Quezon City
Roll of Attorneys No. 171717
IBP No. A-171717
PTR No. A-17171717
MCLE No. A-17171717
 VERIFICATION AND CERTIFICATION
AGAINST NON- FORUM SHOPPING

I, GENUINE WISDOM I. CRUZ, of legal age, after being duly sworn to in accordance with law, depose and
attest:

1. That I am the Petitioner in the above-titled case;

2. 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.

3. 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 tribunals or agency.
4. Should there be any other such case/s that may have been filed, I hereby bind myself to inform the
Court of such fact with five (5) days from the discovery thereof.

IN WITNESS WHEREOF, I have hereunto set our hand this 5th day of November, 2020, City of
Quezon, Metro Manila, Philippines.

GENUINE WISDOM I. CRUZ

Affiant
Issued on: November 5, 2020
Issued at: Quezon City

SUBSCRIBED AND SWORN to before me, a notary public in the City of Quezon, this 5th day of October
2020, City of Quezon, Metro Manila, Philippines, affiant having exhibited to me his Driver’s License No.
17171717 issued at Quezon City, Philippines.

ATTY. NICO B. VALDERAMA, CPA

Notary Public
Until December 27,2020
PTR No. 17171
Issued at Quezon city
On January 12,2022

Doc No .180
Page no. 35
Book No. 2
Series 2020