ACTION FOR CONVEYANCE OF TITLE OBTAINED IN BREACH OF TRUST

COMPLAINT

Plaintiff thru counsel, respectfully alleges unto this Honorable Court:

1. That both the plaintiff and the defendant are of age, and residents of
___________________;

2. That the plaintiff is the legitimate heir of____________ who died in __________
on ___________;

3. That the defendant, prior to the death of said ____________, had been in charge
of certain lands belonging to the deceased, situated in ____________ and more particularly
described as follows, to wit: ________________________________________;

4. That upon the death of the decedent, the defendant continued to take charge and
administer the abovedescribed property for the interest and benefit of the heirs of the deceased;

5. That on _____________, the defendant, through fraud and misrepresentation, and

in breach of trust, and without the knowledge of the heirs of the deceased, succeeded in
registering said property in his own (defendant) name, to the exclusion of the plaintiff and the
other heirs of the true owner thereof;

6. That no rights of innocent purchasers for value have as yet intervened which
would bar an action for conveyance in this case.

WHEREFORE, it is respectfully prayed, that the defendant be ordered to convey the title
he has fraudulently obtained on the lands in question and to transfer the same to the plaintiff and
the other legal heirs of the deceased, with damages and costs.

Other reliefs just and equitable are also prayed for.

(Venue, date, signature)

(Verification, Certification of Non-Forum Shopping)