Republic of the Philippines

REGION XI
LANAO DEL NORTE
MUNICIPAL CIRCUIT TRIAL COURT
ILIGAN CITY
Branch 5

PEDRO SAYSON
Plaintiff,
-versus- CIVIL CASE No. Q-12345
For: EJECTMENT (FORCIBLE ENTRY)

KUTS SARA
Defendant.
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COMPLAINT

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 PEDRO SAYSON, is residing at #123 Narra St., Fairville, Iligan

City, where he may be served with court order and other processes;

2. Defendant KUTS SARA is a resident of #123 Acacia St., Fairville, Iligan

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, JOE ABLE. (A copy of the Deed of Sale is hereto
attached as Annex “A”);

4. The parcel of land, situated in Lot 5 Purok Manga, Barangay Tubod, Iligan
City, is covered by Transfer of Certificate of Title No. 12345 issued by the
Register of Deeds of Iligan City and is more particularly described, as
follows:

(Description)

(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 attorney’s 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;

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 PRAYER

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:

(a) Permanently VACATE the premises in question and give the immediate
right of possession to the Plaintiff;

(b) 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,

(c) 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. Iligan City, Lanao del Norte.

ATTY. HENI WALAYAN

Counsel for Plaintiff
Iligan City
Roll of Attorneys No. 1234567
IBP No. A-1234567
PTR No. A- 1234567
MCLE No. A-1234567

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 VERIFICATION AND CERTIFICATION
AGAINST NON-FORUM SHOPPING

I, PEDRO SAYSON, of legal age, after being duly sworn to in accordance

with law, depose and attest:

That I am the petitioner in the above-titled case; that I have caused the
preparation of the foregoing petition and understood the contents thereof, and I
hereby declare that all the allegations contained therein are true and correct
according to my knowledge and belief.

Furthermore, I hereby certify that I have not filed nor caused to be filed any
other similar case involving the same issues in the Supreme Court, Court of
Appeals or any other tribunal or agency and that, should there be any other such
case/s that may have been filed, I hereby bind myself to inform the Court of such
fact within five (5) days from the discovery thereof.

IN WITNESS WHEREOF, I have hereunto set our hand this 14th day of
February 2020, City of Iligan, Lanao del Norte, Philippines.

PEDRO SAYSON
Affiant
CTC No. 1234565
Issued On: February 14, 2020
Issued At: Iligan City

SUBSCRIBED AND SWORN to before me, in the City of Iligan, this day
of February 14, 2020, City of Iligan, Lanao del Norte, Philippines, affiant having
exhibited to me his Drivers License No. ___________, issued at Iligan City,
Philippines.

ATTY. PINI LEE

Notary Public
Until December 31, 2013
PTR No. A-123056
Issued at Iligan City
On February 14, 2020

Doc. No. 1;
Page No. 1;
Book No. 1;
Series 2020.