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CHRISTINA LAGDAMEO
Plaintiff,
-versus-
COMPLAINT
PLAINTIFF, through the undersigned counsel, and unto this Honorable Court
most respectfully submits this Complaint for Recover of Possession of Real Property
and in support hereof makes the following assertions:
1. Plaintiff CHRISTINA LAGDAMEO, of legal age, Filipino, and residing at #123
Basak, Taloto, Tagbilaran City, where she may be served with court order and
other processes;
2. Defendants SPS. EPIFANIO LAGDAMEO and MERCEDITA LAGDAMEO, both
of legal age, Filipinos, and are residents of #456 Panglao, Bohol where they may
be served with summons, order and other court processes;
3. Plaintiff is the recognized illegitimate child and sole heir of Oswald Lagdameo
who died on March 2, 2000 and that she has been living with him together with
the defendants.
4. Plaintiff asserts that her father initiated adoption proceedings in order to adopt
her but due to the untimely death of Oswald Lagdameo while on duty as a
member of the Armed Forces of the Philippines, the adoption proceedings did not
come into completion. However, the plaintiff presents an Affidavit that Oswald
Lagdameo had attended the adoption proceedings forum. (Attached is a copy of
the Affidavit of Oswald Lagdameo and the Certification of the DSWD marked as
Annex C and D respectively)
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.
November 13, 2014. Tagbilaran City, Bohol
CHRISTINA LAGDAMEO
Affiant
CTC No. 1234565
Issued On: May 4, 2011
Issued At: Quezon City
SUBSCRIBED AND SWORN to before me, in the City of Tagbilaran, this 12th
day of November 2014, City of Tagbilaran, Bohol, Philippines, affiant having ex habited
to me her Drivers License No. 57555 issued at Tagbilaran City, Philippines.
ANNEX A
Republic of the Philippines
Province of Bohol
Municipality of Panglao
Barangay Libaong
OFFICE OF THE LUPONG TAGAPAMAYAPA
Barangay Case No. 2014-005
For: Ejectment
CHRISTINA LAGDAMEO
Complainant
against
Attested:
ANNEX B
DEMAND LETTER
I candidly hope that a judicial action shall not be resorted to as you are doubtless
aware that his will only entail useless and unnecessary expenses, not to mention untold
inconvenience due to protacted court litigation. However, if our demand is not heeded
within the allotted period, court action will be initiated without further notice to you.
Please give preferential attention to this matter.
ANNEX C
AFFIDAVIT
I, Oswald Lagdameo , Filipino citizen, of legal age, single, and a resident of 123
Panglao, Bohol after having been duly sworn in accordance with law, hereby depose
and say:
1. That Christina Lagdameo, Filipino citizen of legal age, and a resident of
Basak, Taloto, Tagbilaran City, Bohol is my illegitimate daughter.
2. That I have initiate adoption proceedings for the purpose of adopting
Christina to improve her legitimacy.
Oswald Lagdameo
Affiant
SUBSCRIBED AND SWORN before me this 8th day of July 2014, by Oswald
Lagdameo who exhibited to me his Voters ID No. 12244 issued on .March 5, 1995 at
Panglao, Bohol
ATTY. LAWRENCE LOUIE G. UY
Notary Public
Tagbilaran City
Roll of Attorneys No. 1234567
IBP No. A-1234567
PTR No. A- 1234567
MCLE No. A-1234567
Doc. No. 12;
Page No. 1;
Book No. 1;
Series 1997.
ANNEX D
CERTIFICATION
This is to certify that Oswald Lagdameo had attended and participated in the
Adoption Forum that was held on January 3, 1997 at the DSWD Office, Tamblot Street,
Tagbilaran City, Bohol for the purpose of adopting his illegitimate daughter, Christina
Lagdameo.
Juan De la Cruz
DSWD Bohol Head
ANNEX E
OFFICIAL RECEIPT
This is to certify that the required filing fee of FIVE HUNDRED FIFTY PESOS
(550) has been paid by herein Plaintiff to this honorable court.