THE PARTIES

PLAINTIFF, Republic of the Philippines, represented by the Department of

Engineering and Public Works, Manila, respectfully states:
1. Plaintiff, through the Department of Engineering and Public Works, Manila is
a juridical entity recognized by law as a government agency mandated to
deliver/serve the public in the field of engineering services, building permit
applications, allied services and enforcement of laws inherent with its frameworks
and City-wide implementation of infrastructure projects pursuant to the provision
of P.D. 1096 and other applicable laws of the Philippines 1. It is constituted for
purposes of this suit by City Engineering Department of the City of Manila
with address at R328, Manila City Hall, Padre Burgos Ave., 659 Ermita, Manila
City, where it may be served with notices, orders and other processes of the
Honorable Court.

2. Defendant Spouses Juan and Juanita Bonanza owned a two-hectare land

covered by TCT No. T-12345 and mortgaged it to Bank of the Philippine Islands
(BPI) under entry number 12031991, and to the Philippine National Bank (PNB)
under entry number 03121991. Juan and Juanita Bonanza may be served with
notices, orders, and other court processes of the Honorable Court in Delpan,
Tondo, City of Manila.

3. Defendants Bank of the Philippine Islands (BPI) and Philippine National

Bank (PNB) are corporations and both mortgagees of the land covered by TCT
No. T-12345. BPI and PNB may be served with notices, orders, and other court
processes of the Honorable Court in Delpan, Tondo, City of Manila.

1
Engineering and Public Works (See https://manila.gov.ph/engineering-public-works/, last accessed on 16 October
2021).
4. Defendant Reynaldo Dela Cruz is the owner of the land covered by TCT No. T-
54321 and mortgaged it to Security Bank under the entry number 19910312.
However, the said land was already sold to the Megawide Corporation, however,
the title was not yet transferred and executed in favor of the latter. He may be
served with pleadings, notices, orders, and other court processes of the
Honorable Court in Delpan, Tondo, City of Manila.

5. Defendant Security Bank is a corporation and mortgagee of the land covered by

TCT No. T-54321. Security Bank may be served with notices, orders, and other
court processes of the Honorable Court in Delpan, Tondo, City of Manila.

6. Defendants Lilia Bahing’s family and Lilo Morano’s family are the occupants
of lands covered by TCT Nos. T-12345 and T-54321. Furthermore, the
defendants are not the owners nor lessees of the said lands. The two (2) families
may be served with pleadings, summongs, orders, and other processes of the
Honorable Court in City of Manila.