Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT

QUEZON CITY

Branch 031

JUAN AYSION SANTOS

Plaintiff,

-versus- CIVIL CASE No. Q-12345

For: EJECTMENT (FORCIBLE ENTRY)

JOHN CHIU CO

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 JUAN AYSION SANTOS, is residing at #123 Narra St., Fairville, Quezon City,
where he may be served with court order and other processes;
2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville, Quezon 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, JANICE DY LEE. (A copy of the Deed of Sale is hereto attached as Annex
“A”);
4. The parcel of land, situated in #129 Fairville, Barangay Pangsy, QuezonCity, is covered by
Transfer of Certificate of Title No. 12345 issued by theRegister of Deeds od Quezon City
and is more particularly described, asfollows:(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 JUDICIAL FORMS (SUMMARY PROCEEDINGS),
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;

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. Quezon City, Metro Manila.

ATTY. PHOEMELA G. CRUZ

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