Republic of the Philippines MUNICIPAL TRIAL COURT IN CITIES Third Judicial Region Cabiao, Nueva Ecija ANTONIA, Plaintiff

-VersusCARLITO, Defendant x---------------------------------------------x COMPLAINT Plaintiff through respectfully avers that:

1.

CIVIL

CASE

NO.

001-01

FOR: FORCIBLE ENTRY

counsel,

unto

this

Honorable

court

The plaintiff is of legal age, Filipino and a resident of Cabiao , Nueva Ecija;while the defendant is also of legal age, Filipino and a Resident of Cabiao Nueva Ecija.

2.

The plaintiff was a possessor and a farm beneficiary of a parcel of agricultural land registered under the name of Benito located at Cabiao Nueva Ecija with a TCT No. 12345 issued by Registry of Deeds of Nueva Ecija.

3.

The plaintiff bought the land from Benito in the year 2002.

4.

The defendant occupied a portion of the land bought by the plaintiff.

5. The plaintiff suffered sleepless nights, social humiliation, besmirched reputation and other similar wounded feelings for which moral damages should be awarded.

6. The plaintiff has to serve the services rendered by the counsel and will

incur litigation cost by unjust action of the defendant, for which Attorneys fees of Php 20,000 plus the appearance fee of Php 2,000 per hearing, and litigation cost of not less than Php 10,000 should be meted against the defendant.

WHEREFORE, it is respectfully prayed that, after due hearing, judgment be rendered in favor of the plaintiff for: 1. Ordering the defendant to vacate the premise.
2. Holding the Defendant liable for Moral damages, Attorneys Fees

plus Appearance fees and litigation costs. IN WITNESS WHEREOF, I have hereunto affixed my signature this 1ST day of September 2010, at Cabaio, Nueva Ecija

ATTY. CONRADO A. REYES III (Attorney for the Plaintiff) VERIFICATION REPUBLIC OF THE PHILIPPINES ) CABIAO, NUEVA ECIJA ) S.S I, ANTONIA, Filipino, of legal age residing at Cabiao, Nueva Ecija, after being sworn to in accordance with the law, deposes and say that: 1. I am the plaintiff in the above entitled case; 2. The facts stated in the above complaint are true and correct. 3. I have not commenced any action filed any claim involving the same issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such other action or claim is pending in them; and 4. If I should learn the same or similar action or claim has been filed is pending after its filing, I shall report the fact within five (5) days from notice to the court where the complaint or initiatory pleading has been filed. IN WITNESS WHEREOF, I have hereunto affixed my signature this 2nd day of September 2010, at Cabiao, Nueva Ecija.

(Signed) ANTONIA

SUBSCRIBED AND SWORN TO BEFORE ME, this 1st day of September 2010, in the Municipality of Cabiao,Nueva Ecija identified thru LTO Professsional Drivers License No. C055-09876, issued by LTO Cabanatuan on December 28, 2009 and Community Tax Certificate with CTC No. 123456 issued on January 25, 2010 and issued at Cabiao, Nueva Ecija

ATTY. FERMIN C. ROMANO NOTARY PUBLIC Commission Serial No. 1 Roll of Attorney 556677 IBP No. 01-6758 PTR No. 88995

Doc. No. 1 Page No. 1 Book No. 1 Series of 2010