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Republic of the Philippines

Municipal Trial Court in Cities

Branch 8
Baguio City, Benguet
PLAINTIFF, through the undersigned counsel, and unto this
Honorable Court most respectfully submits this Complaint for Forcible
Entry and in support hereof makes the following assertions:
1. Plaintiff JUAN AYSION SANTOS, is residing at #123 Narra St.,
Fairville, Quezon City, where he may be served with court order
and other processes;
2. Defendant JOHN CHIU CO is a resident of #123 Acacia St.,
Fairville, Quezon City where he may be served with summons,
order and other court processes;
3. Plaintiff became owner of a certain parcel of land, through a
Deed of Sale from the original owner, JANICE DY LEE (A copy
of the Deed of Sale is hereto attached as Annex A);
4. The parcel of land, situated in #129 Fairville, Barangay Pangsy,
Quezon City, is covered by Transfer of Certificate of Title No.
12345 issued by the Register of Deeds of Quezon City and is
more particularly described, as follows:
(Copy of TCT- 12345 is hereto attached as ANNEX B);

5. Herein Defendant, through stealth and strategy, occupied the

parcel of land in question and refuses to vacate the same
despite repeated oral and written demands. (Copy of the
written demand is hereto attached as Annex C);
6. The same acts of the Defendant compelled the Plaintiff to incur
damages consisting of attorneys fees in the amount of Thirty
thousand pesos (P30,000.00) pesos and filing fee, cost of
transportation and other miscellaneous accommodation of its
lawyers and other personal expenses to be incurred in
attending the hearings of this case in the amount of FIFTY
THOUSAND PESOS (Php 25,000.00).
7. This action is governed by the Rules on Summary Procedure;

WHEREFORE, premises considered, it is respectfully prayed of
this Honorable Court that, after the proceedings, judgment be
rendered in favor of the Plaintiff and ordering the Defendant and all
persons claiming rights under him to:
1. Permanently VACATE the premises in question and give the
immediate right of possession to the Plaintiff;
2. Pay plaintiff the amount of Thirty Thousand Pesos (P30,000.00)
by way of attorneys fees and Twenty Five Thousand Pesos
(P25,000.00), by way of other litigation expenses; and,
3. Pay the cost of this suit.
Plaintiff prays for such other remedies and reliefs as may be
deemed just and equitable under the premises.
May 1, 2011. Quezon City, Metro Manila.


Counsel for Plaintiff
No. 123, Camp Allen, Baguio City
Tel. No. (074) 424-4187
Roll No. 123456 04-10-2011

PTR No. 123456; 1-03-2011; Baguio City

IBP Lifetime No. 123456; Baguio Benguet
MCLE Compliance No. 1245 2011
I, JUAN AYSION SANTOS, a Filipino, of legal age, and a
resident of 67 Green Valley Subdivision, Baguio City, subscribing
under oath, hereby deposes and states that:
(1)I am the complainant in the instant case;
(2) I have read the foregoing Petition and the allegations therein
are true and correct of my own knowledge and/or based on the
records on hand; and
(3) I attest to the authenticity of the annexes thereof.

I certify further that:

(1) I have not commenced any other action or proceeding
involving the same issues in the Supreme Court, the Court of
Appeals, or different Divisions thereof, or any other tribunal or
(2) No such action or proceeding is pending in the Supreme Court,
the Court of Appeals, or different Divisions thereof, or any other
tribunal or agency; and
(3) If I should learn that a similar action or proceeding has been
filed or is pending before the Supreme Court, the Court of
Appeals, or different Divisions thereof, or any other tribunal or
agency, I hereby undertake to notify this Honorable Court within
five (5) days from such notice.
IN WITNESS WHEREOF, I have hereunto set our hand this 1 st
day of May 2012, City of Quezon, Metro Manila, Philippines.



CTC No. 1234565

Issued On: May 4, 2011
Issued At: Quezon City
SUBSCRIBED AND SWORN to before me, in the City of
Quezon, this 1st day of May 2012, City of Quezon, Metro Manila,
Philippines, affiant having ex habited to me his Drivers License No.
___________, issued at Quezon City, Philippines.


Notary Public
Until December 31, 2013
PTR No. A-123056
Issued at Quezon City
On January 1, 2012
Doc. No. 1;
Page No. 1;
Book No. 1;
Series 2012.