Republic of the Philippines )

City of Iligan )
x----------------------------------X

I. JUDICIAL COMPLAINT AFFIDAVIT OF MARIA CLARA

Preliminary Matters:

MARIA CLARA is 29 years old, Filipino, single and a resident of Brgy.

Tubod, Iligan City. She is a business woman.

Atty. Apolinario Mabini, with office address at Brgy. Tubod, Iligan

City is the one conducting/supervising the examination of the witness held
at this law office in the above given address.

Affiant is answering the questions asked, fully conscious of being under

oath and aware of being under pain of criminal liability for false testimony
or perjury.

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1. Q: For the record, Ms. Witness, may I know why you are in my office
today?
A: I am here, attorney, to request you to take my judicial affidavit
because I want to file a case of recovery of possession against Gregorio
Del Pilar.

2. Q: Who is this Gregorio Del Pilar are you talking about?

A: He is a friend of mine, who pleaded to allow him and his family
to occupy a parcel of land that I own.

3. Q: Why do you want to file a case for recovery of possession against

Gregorio Del Pilar?
A: I am the true and registered owner of a parcel of land, located in
tubod Iligan City. Sometime in December 2018, Gregorio Del Pilar, a
friend of mine pleaded to allow him and his family to occupy such
aforementioned land. Since the land is empty and unused, I allowed
him and his family to occupy the same with the condition that they
must vacate upon demand.

4. Q:What happened next?

A: Sometime in year 2019, I demanded the Gregorio Del Pilar and
his family to vacate the said property but the latter refused and still
continue to occupy.
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 On December of 2022, there was a wild fire causing the temporary
house of Gregroio Del Pilar and his family, including the the land to be
gutted by fire. As s result thereof, I decided to cordon the area and
instructed Gregoria Del Pilar and his family to vacate the premises,
however, the latter again refused to turn over the property and
instead constructed a new house thereat.

5. Q: Do you have evidence to prove your claim?

A: Yes. I have a copy of the Transfer Certificate of Title of the parcel
of land.

6. Q: What do you want to do with this Transfer Certificate of Title?

A: I want to attach the same to my complaint.

7. Q: What did you do next, If any?

A: I went to your office last March 20, 2023 and requested you to
send a demand letter on my behalf.

8. Q: Do you have a copy of that demand letter?

A: Yes, I kept one for my file.

9. Q: Would you be willing to attach this as an annex on your judicial

affidavit?
A: Yes.

10. Q: Do you know if Gregorio Del Pilar received the demand letter?
A: Yes Sir, I have a copy of the demand letter, received by him, and
with his signature.

11. Q: Would you be willing to attach this as an annex in this case?

A: Yes.

12. Q: What is the response of Gregorio Del Pilar to the demand letter?
A: He did not respond at all. It all fell on deaf ears that is why I am
compelled to file this legal action.

13. Q: Do you have anything more to say?

A: No more attorney.

14. Do you affirm and confirm the veracity of your statements herein?
A: Yes, I do.

IN WITNESS WHEREOF, I have hereunto set my hand this 10 th day of

April, 2023 at Iligan City, Philippines.
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 MARIA CLARA
Affiant

SUBSCRIBED AND SWORN to before me this 10th after affiant exhibited

to me her Valid Identification.

Atty: X
Notary public for Lanao Del Norte and
Roll No:
IBP Lifetime no:
PTR no:
MCLE no:
Iligan City and Lanao Del Norte
Until 31st December 2024
Doc No:
Page No:
Book No:
Series of 2023

ATTESTATION

I, Atty Apolinario Mabini with above mentioned Law Office address,

hereby depose and state, that:

1. I was the one who conducted/ supervised the examination of the

witness;
2. I have faithfully recorded or caused to be recorded the questions I asked
and the corresponding
3. No one has coached the witness in giving his answers; and
4. I attest to the truth of the foregoing and for whatever legal purpose it
may serve, under the pain of legal consequences and disciplinary including
disbarment.

Done in the day and place above mentioned.

APOLINARIO MABINI
TIN Number:
Issued on:

3
 SUBSCRIBED AND SWORN to before me this 10th after affiant exhibited
to me her Valid Identification.

ATT Y: X
Notary public for Lanao Del Norte and
Roll No:
IBP Lifetime no:
PTR no:
MCLE no:
Iligan City and Lanao Del Norte
Until 31st December 2024
Doc No:
Page No:
Book No:
Series of 2023