REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

Fifth Judicial Region
Legazpi City, Albay
Branch _

HAYSLI I. LUCILO
Plaintiff,

-versus- CIVIL CASE No. 003

For: Forcible Entry with Damages

HELEN H. MABINI
Defendant,

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COMPLAINT

Plaintiff, by counsel, respectfully states that:

(1) Plaintiff HAYSLI I. LUCILO, is of legal age and resident of #298, Purok 6, Brgy.
Bonot, Legazpi City;

(2) Defendant HELEN H. MABINI, of legal age, and a resident of #568, Purok 8, Brgy.
Rawis, Legazpi City, whereat she may be served with court order and other processes;

(3) Plaintiff as the registered owner of a certain parcel of land denominated as Lot No.
25478 located at #185 Purok 10, Brgy. Bitano, Legazpi City is covered by Transfer of
Certificate of Title No. 789456, which duly certified copy is hereto attached as
“ANNEX A” and made an integral part hereof;

(4) On January 1, 2017, plaintiff discovered that defendant entered the subject property
through stealth and strategy and continues to occupy said property as of this date;

(5) That on January 10, 2018, with the assistance of lawyer, plaintiff sent a letter
requesting defendant to vacate the property, herein attached in the original as
“ANNEX B” but the request was ignored by herein defendant;

(6) Plaintiff sought the assistance of the Lupon ng Barangay to demand the defendant to
peacefully and voluntarily vacate the subject property but no settlement was reached
therein, a copy of the Certificate to File Action issued by the Punong Barangay is
hereto attached as “ANNEX C”;

(7) Through the acts done by the defendant, the Plaintiff incurred damages consisting of
attorney’s fees in the amount of FIFTY THOUSAND PESOS (Php 50, 000.00) as well
as filing fee, cost of transportation and other miscellaneous and personal expenses
incurred and will incur in attending hearings and conferences for this case in the
amount of FIFTY THOUSAND PESOS (Php 50, 000.00)

(8) This action is governed by the Rules on Summary Procedure;

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 PRAYER
WHEREOF, premises considered, it is most respectfully prayed unto this Honorable
Court that, after hearing, judgement be rendered ordering the defendant to:

1. Permanently vacate the premises subject of this complaint and give the immediate
right of possession to the Plaintiff;
2. Pay the Plaintiff the amount of FIFTY THOUSAND PESOS (Php 50, 000.00) by way
of attorney’s fees and FIFTY THOUSAND PESOS (Php 50, 000.00) by way of other
litigation expenses ;
3. Pay the expenses of this suit;

The Plaintiff prays for such other remedies and reliefs as may be deemed just and equitable
under the premises .

City of Legazpi, January 18, 2018.

ATTY. ANGELICA BELLADONNA C. LEONOR

Counsel for the Plaintiff
Unit 852, Legazpi Bldg. 658
Bonot, Legazpi City, Albay

Roll of Attorney No. _ _ _ _ _

IBP No. _ _ _ _ _

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