Republic of the Philippines

REGIONAL TRIAL COURT

Branch ____
Banaue, Ifugao

MUNICIPALITY OF MAYOYAO, CIVIL CASE NO. ___

IFUGAO, as represented by the FOR: EMINENT DOMAIN
Municipal Mayor, HON. RONNIE
LUMAYNA
Plaintiff,

-versus-

JOSE A. BOGWANA
Defendant.
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COMPLAINT
COMES NOW the plaintiff through the undersigned counsel, and unto this
Honorable Court, respectfully avers:

1. THAT the plaintiff is a ______;

2. THAT the defendant is of legal age, married and a resident of ___;

3. THAT the plaintiff, by virtue of Municipal Ordinance No. 1, series of 2018

has the power to exercise the right of eminent domain and to take private
property for public use;

4. THAT the following described property, together with all the

improvements thereon, is a private property, owned by the Mr. Jose A.
Bogwana, to wit:

“Irrigational Riceland with an area of Two Thousand Eight Hundred

Eighty (2, 880) square meters bounded by North – Bufo Panapon,
East – Sato and L. Tocgad, South – J. Langbayan and L. Tocgad, and
West – Langbayan and N. Wahawa and Panapan.”

5. THAT the above – described property is herein sought to be condemned in

order to convert the same into Municipal Hatchery, which is avowedly a
public purpose;

6. THAT the plaintiff hereby tenders and offers to deposit such sum as may
provisionally be ascertained and fixed by this Honorable Court so that,
 pending these proceedings, the plaintiff may immediately be placed in
possession of the property involved;

WHEREFORE, premises considered, it is most respectfully prayed:

a. THAT after due notice and hearing, an order of condemnation be entered,

declaring that the plaintiff has a lawful right to take the said properties
herein sought to be condemned for the public use hereinabove specified,
upon payment of just compensation to be determined as of the date of
taking of the said property;

b. THAT upon the entry of the order of condemnation, three (3) competent
and disinterested persons be appointed as Commissioners to ascertain and
report to the court the just compensation for the property condemned;

c. THAT, pending these proceedings, the plaintiff be placed in possession of

the property involved upon deposit with the National Treasurer of such
sum as may provisionally be ascertained and fixed by this Court, subject to
the orders and final disposition of the same.

Lagawe for Banaue, Ifugao this ____ day of ____, 2018.