REPUBLIC OF THE PHILIPPINES

OFFICE OF THE CITY PROSECUTOR

CITY OF ________
A,
Complainant,

I.S. No. _____________________

- versus -

For: USURPATION OF REAL

RIGHTS
IN
PROPERTY
PUNISHED UNDER ARTICLE 312
OF ACT NO. 3185 OTHERWISE
KNOWN AS THE REVISED
PENAL
CODE
OF
THE
PHILIPPINES AS AMENDED.

B
Respondent.
x---------------------------------x
COMPLAINT-AFFIDAVIT
THE UNDERSIGNED COMPLAINANT respectfully alleges:
I, A, of legal age, Filipino, single with business and postal address
at______________________________________, after having been
duly sworn to in accordance with law, hereby accuses:
B,
Filipino,
single
and
a
resident
of
_________________________where summons and notices may be
served for the crime of Occupation of real property or usurpation of
real rights in property committed as follows:
1. That, I am the owner of a parcel of land covered by Transfer
Certificate of Title No. _______;
2. That, said parcel of land was illegally occupied by B without my
approval;
3. That, I demanded from B to vacate my property as evidenced
by a demand letter dated ________ a copy of which is attached
hereto and made an integral part hereof;

4. That on _________ I visited said property and discovered that

B vacated the same;
5. However, B fenced my property without having the right of
possession, usurping my real rights thereto;
6. That by fencing the said property, I was prevented by B from
entering and exercise all rights of ownership over the same;
7. I am executing this sworn statement for the purpose of charging
the respondent with having committed the crime of
USURPATION OF REAL RIGHTS IN PROPERTY punished
under ART. 312 OF ACT NO. 3185 otherwise known as the
REVISED PENAL CODE OF THE PHILIPPINES as amended.
Muntinlupa City for Bacoor City, Cavite, January 08, 2015.
A
Complainant

VERIFICATION/CERTIFICATION
I, A, after being sworn to in accordance with law, hereby depose
and state:
1. That I am the complainant in the above-captioned case;
2. That I have caused the preparation and filing of the foregoing
complaint;
3. That I have read and understood the contents thereof and
attest that the allegations therein are true and correct according to
my personal knowledge;
4. That I certify that I have not commenced any other action or
proceeding involving the same issues in the Supreme Court, Court of
Appeals, or any other court/tribunal/agency of the Court, and to the
best of my knowledge, no such action or proceeding is pending
before the Supreme Court, the Court of Appeals or any other
court/tribunal/agency of the court and if there is any such action or
proceeding which is either pending or may have been terminated, I
undertake to report the fact within five days to this Honorable Court
where the complaint is filed.
SUBSCRIBED AND SWORN to before me, this ____ day of
____________ in__________________________________, by:
NAME