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ABC DEF
Plaintiff, Special Proceeding Case No. 999
vs.
GHI JKL
Respondent
COMPLAINT COMES NOW the plaintiff by the undersigned attorney, and unto this Honorable
Court, respectfully avers:
1. That the plaintiff and the defendant are both of age, and residents of #1 Lourdes St.,
Pasay City;
2. That the said parties are co-owners, by virtue of intestate inheritance from their
deceased parents, of certain real properties located in #12 Lourdes St., Pasay City, more
particularly described as follows, to wit: (Description of the estate of which partition is
demanded)
3. That the plaintiff desires that the above real estate be partitioned between the plaintiff
and the defendants;
4. That the plaintiff has requested of the defendant that the above described real estate be
amicably partitioned between them by mutual agreement, but the said defendant refused and
continues to refuse to do so.
WHEREFORE, it is respectfully prayed: (a) That, after due hearing, the partition of the
above-described real estate be ordered between the plaintiff and the defendant, share and share
alike; (b) That the costs and expenses of these proceedings be taxed solely against the defendant.
Other reliefs just and equitable under the premises are likewise prayed for.