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Fifth Judicial Region
Branch ____

CIVIL CASE NO: __________

x------------------------------------- x

PLAINTIFF, by counsel and to this Honorable Court respectfully

1. Plaintiff is of legal age and a resident of _________________

while Defendant is also of age and resident of
__________________, where they may be served with summons
and other legal processes.

2. Plaintiff is the owner and in possession of a parcel of

agricultural land located in _____________________ since
____________, which he has since devoted to planting vegetable,
until the date and incident hereunder alleged, and which is
being looked after by his encargado, ______________ for and on
behalf of Plaintiff.

3. On or about ____________, Defendant, by means of force,

strategy, and stealth, unlawfully entered said parcel of land
and ejected Plaintiff’s encargado, for and on Plaintiff’s behalf,
and prevented him from entering the parcel of lands by force.

4. Since the date above-mentioned, Defendant have remained in

illegal possession of the parcel of lands, harvesting the
vegetables therein planted for themselves, and up to the
present still retain such possession thereof.

5. The reasonable rental value of the said parcel of land is P

_________________ a month and the damage to the vegetables
therein planted amounted to P _________________.

6. Plaintiff filed a complaint with the Office of Tagapamayapa but

efforts of the latter proved futile, as Defendant adamantly
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refused to vacate the premises, constraining the Lupon
Tagapamayapa to issue a certificate to file the instant
complaint, copy of which certificate is attached hereto as Annex

WHEREFORE, Plaintiff prays that judgment be rendered

ordering Defendant and all those acting for their behalf to vacate the
land in question and to restore possession thereof to Plaintiff to pay P
__________ per month from the time of unlawful entry to the time
possession is restored to Plaintiff as well as damages in the amount of
P_______________ with legal interest thereon, plus cost.

Legazpi City, Albay, Philippines. June 7, 2016.






I, _______________________________, of legal age, , Filipino Citizen, and a

resident of _____________________________, after being sworn to in accordance with
law, depose and say;

1. That as the Plaintiff, I have read the Complaint and the allegations
therein are true and correct of my own knowledge or based on
authentic records;

2. That I have caused the preparation of this Complaint;

3. That no other action or any other proceedings have been filed involving
the same issues in any court, tribunal or quasi-judicial agency and to
the best of my knowledge no such other action or proceedings is
pending therein;

4. That, if I should thereafter learn that the same or similar action or

proceeding has been filed or is pending, I shall report that fact within
five (5) days therefor to the Court.

IN WITNESS THEREOF, I have hereunto set my hands this _____day of

_____________ 2016 Legazpi City, Albay, Philippines.
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Competent ID No: _________________

SUBSCRIBED AND SWORN TO before me, a Notary Public in and for the
Province of Albay, this _______ day of ________ 2016, petitioner personally appeared
and known to me to be the same person who executed the foregoing document,
through the competent proof of identity indicated below his/her name.

Doc No.: _____;

Page No.: ____;
Book No.: ____;
Series of 2016.

Table of Annexes:

Annex A - Certificate to File Action

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