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Republic of the Philippines

5
th
MUNICIPAL CIRCUIT TRIAL COURT
Second Judicial region
Naguilian, Isabela


DONALD CASTILLO
Plaintiff Civil Case No.
-vs- Forcible Entry and Damages
Atty. RAMIREZ
Defendants.
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COMPLAINT
PLAINTIFFS by counsel, to this Honorable Court respectfully avers that,
1. Plaintiff DONALD CASTILLO, of legal age, Filipino and residents of MArasat Pequno, San Mateo,
Isabela.
2. Defendant Atty. Ramirez, Filipino is residents of Naguilian, Isabela, where they may be served
summons and other processes.
3. The plaintiff is the owner of a parcel of land located in San Mateo, Isabela, containing an area of
ONE MILLION(1,000,000.00) SQUARE METERS, more or less which realty is titled in the name as
evidence by Transfer Certificate of title No. T-222222222 of the Registry of Deeds of Isabela,
photocopy of TCT No. T-222222222 is hereto attached and made an integral part of Annex A.
4. Plaintiff, by themselves and through their predecessors in-interest, have been in peaceful
possession of the land continuously and uninterrupted for more than fifty (50) years;
5. On January 28, 2011, defendant together with hired laborers without the knowledge, consent
and authority of the plaintiff, by force, strategy and stealth entered the land described in
paragraph 3, encroached on and took possession of a portion of the land having an area of
500,000 square meters with the following bounderies: on the Northeast by the remaining
portion; and on the Southwest by a provincial Road.
6. Simultaneous to their unlawful entry, defendant started construction of a residential house
notwithstanding repeated demands for them to stop and to desist from further acts of
dispossession.
7. Plaintiff, by themselves and through their representative, repeatedly demanded of the
defendant to vacate the area occupied by them and and to deliver the peaceful possession of
the same to them, but defendants, without any just or legal reason, refused and continue to
refuse to leave the premises and restore peaceful possession to the plaintiffs of the portion
which they unlawfully wrested from the plaintiff.
8. Efforts for a possible settlement and/or reconciliation was exerted by the plaintiff by seeking the
intervention of barangay officials of Barangay Marasat Pequeno, san Mateo, regrettably all
efforts to amicably settle their dispute were in vein. Copy of the certification issued by Barangay
Secretary Levy teodorao dated feb. 9, 2011 is hereto appended and marked as Annex B.
9. As a consequence of the unlawful entry and occupation of their land by the defendant and their
subsequent refusal to vacate the premises, plaintiff were compelled to file this action and, for
this reason have to engage the services of counsel for an agreed professional fee of P25.00
10. As further consequence of the defendant refusal to surrender and restore peaceful possession
of the land, plaintiff, suffered mental anguish, emotional disturbance, embarrassment
besmirched reputation which entitles them to recover moral and exemplary damages
amounting to not less than P50,000.00
PRAYER
WHEREFORE, plaintiff respectfully prays the Honorable Court to render judgment;
1. Ordering the defendant to vacate the premises of the area occupied by them and to deliver
peaceful possession of the same to the plaintiff or their representative
2. Ordering the defendant to remove any and structure which they, in bad faith, have erected in
the area occupied by them or, in default thereof, to order the demolition of their building or
structures which are standing in the land, all at the expense of the defendants.
3. Condemning the defendant to pay to the plaintiff.
a. The sum of P25,000.00 as attorneys fees and the sum of P5,000 as expense of litigation;
b. Moral and exemplary damage of not less than P50,000.00; and
c. The costs of this suit:
d. Plaintiff pray for other reliefs and remedies as may be just and equitable in the
premises.
Ilagan, Isabela, march 2, 2012

ATTY. LEIF JOHN L. ROBINO
Counsel for the Plaintiff
PTR No.


VERIFICATION AND CERTIFICATION
I, Donald Castillo, of legal age, Filipino and resident of MArasat Pequeno, after being
sworn to in accordance with law hereby depose and state:
1 .I am the Plaintiff in the above entitled case.
2. I have caused the preparation and filing of this complaint
3. I have read and understood the contents of this complaint and all the allegation
contained therein are true and correct of our own knowledge and based on authentic
documents.
4. I hereby certify that I have not commenced any other action or proceedings involving
the same issues in the above entitled case before the Supreme Court, Court of Appeals of Justice
or quasi-judicial body, or government agency; and should I learn of a similar action or
proceeding and/or the pendency thereof before any other Court of Justice, quasi-judicial body
or government agency, I do hereby undertake to report the same within (5) days there from to
this Honorable Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this ___ day of March 2012
at Ilagan, Isabela.

Donald Castillo
Plaintiff

Subscribed and Sworn to befor me this ___ day of March 2012 at Ilagan, Isabela.

Doc. No ______
Page No. _____
Book No.______
Series of 2012.