REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

Regional Trial Court, Branch ____
Quezon City

ARNOLD ABBA,
Plaintiff,

-versus- Civil Case No. ____

For: Annulment of Title

VIC VITO,
Defendant.

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COMPLAINT

Plaintiff, thru counsel, respectfully states that:

1. Plaintiff Arnold is a Filipino, of legal age, married, and a resident of 111

Acacia St., Quezon City, where he may be served with orders, notices, and other
processes issued by the Honorable Court;

2. Defendant Vic Vito is a Filipino, of legal age, married, and a resident of 222
Valencia St., Manila City;

3. The Plaintiff is the registered and lawful owner of a parcel of land located at
Quezon City under Transfer Certificate of Title No. T-12345, and more particularly
described as follows:

“… A parcel of land Lot No. 1578 of the Green Plains Subdivision,

Pls-62, Cadastral Case No. N-2 LRC Cadastral Redords No. N-16 with
the improvements thereon situated in the Cubao, Quezon City.Bounded on
the NE., points 1-2 by Lot 1577; on the NW.,points 2-3, by lot 1576; on the
NE., points 3-4, by Road; and on the SE., points 4-1, by Lot 1579.
Containing an area of SEVEN HUNDRED AND FIFTY ONE (751) square
meters, more or less…”

A certified true copy of the TCT No. T-12345 is herein attached as Annex “A”;

4. On 1 January 2020, the Defendant, acting fraudulently and under false

pretenses, sold the lot to a certain Fernando Francisco. A copy of the Deed of Sale
between the two is herein attached as Annex “B”;

5. Because of the fraudulent acts and false pretenses of the Defendant, a new
Transfer Certificate of Title No. T-78999 was issued to Fernando Francisco, to the
prejudice of the Plaintiff. A copy of TCT No. T-78999 is herein attached as Annex “C”;

6. To aid the Plaintiff in the recovery of the property, they have been compelled
to secure the services of counsel whose fees are agreed upon in the amount of P50,000;
and,

7. Under the law, when the title of a person arose from fraud, false pretense, and
misrepresentation, it may be declared cancelled or void by the court. Furthermore, the
court may order that the title over such property be awarded back to the previous owner;

PRAYER

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 WHEREFORE, premises considered, Plaintiff respectfully prays before this
Honorable Court that after trial:

1. The Transfer Certificate of Title No. T-78999 in the name of Fernando

Francisco be cancelled;

2. The Transfer Certificate of Title No. T-12345 in the name of the Plaintiff be
reinstated and declared to be valid;

3. The Defendant be ordered to pay P50,000 as attorney’s fees.

Other reliefs just and equitable are likewise prayed for.

12 January 2020, Quezon City.

(sgd.)
Atty. JOHN JOSIO
Counsel for Plaintiff
Address:
Phone Number:
E-mail Address:
Roll No:
IBP:
PTR:
MCLE:

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, ARNOLD ABBA, Filipino, of legal age, married, and a resident of 111 Acacia
St., Quezon City, respectfully states that:

1. I am the plaintiff in the above case;

2. I have read the pleading, and the allegations therein are true and correct, of my
own personal knowledge and beliefs, and are based on authentic records;

3. I have not commenced any action or filed any claim involving the same issues
in any court, tribunal, or quasi-judicial agency, and to the best of my knowledge, no such
other action or claim is pending therein; and,

4. If I should learn thereafter that the same or similar action or claim has been
filed or is pending, I shall report that fact within 5 days therefrom to the court where this
complaint has been filed.

(sgd.)
ARNOLD ABBA
Affiant

SUBSCRIBED AND SWORN to before me, the affiant ARNOLD ABBA

exhibiting to me his government-issued Driver’s License No. _____ issued on _____ at
______, and with expiration date on _____, as competent evidence of his identity.

12 January 2020, Quezon City.

NOTARY PUBLIC
Commission Serial No:

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 Until 31 December ___
Roll:
IBP:
PTR:
MCLE:

Doc. ___
Page ___
Book ___
Series of ____