COMPLAINT 
(With Urgent Prayer for the Issuance of a Writ of Possession) 
 
 
 
18. Plaintiff intends to present
____________________________, as its witness. He will testify
about the CALAX project, its purpose, the procedures the DPWH
underwent and the documents they procured before the filing of
the present complaint. He will also identify and authenticate the
aforesaid documents in support of this expropriation case. A copy
of his Judicial Affidavit is attached herein as _________ and
forms an integral part of this Complaint. 

PRAYER
 
WHEREFORE, Plaintiff respectfully prays that the Honorable
Court: 
 
1. ISSUE a Writ of Possession upon Plaintiff’s deposit of
the amount equivalent to 100% of the current relevant BIR zonal
value of the affected area of the subject lot and replacement cost
estimate of the improvements thereon;