Republic of the Philippines

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
Branch__, Baguio City
MR. GIAN, TABANGIN
Plaintiff,
Civil Case No.: ___
-versusFOR: violation of PD 1067 and
other environmental laws
MR X, MR Y MR Z, et al
Defendant.
x----------------------------x
COMPLAINT
COMES NOW, plaintiff, in the above entitled Case, through the
undersigned counsel and unto this Honorable Court, respectfully states:
(1)That plaintiff is a Filipino Citizen, of legal age and a resident of #669
Green Road, Camp 7, Baguio City. Where he may be served with
summons and other processes;
(2) That the defendants are all residents of Camp 8 Baguio City where
they may be serve with summons and other processes;
(3)That Camp 8 watershed was declared by Proclamation no.107 as
watershed which covers the area of Lote No. 105-B.A parcel of
land (lot No. 105-B of the subdivision plan Swo-14494, being a
portion of lot No. 105, residence section J, Baguio townsite, G. L. R.
O. Record No. ), situated in the residence section J, City of
Baguio Bounded on the NE. by lot No. 100-B, residence section A; on
the SE., by lot No. 105-A of the subdivision plan; and on the NW., by
lot No. 100-B of residence section A. Beginning at a point marked
1 on plan, being S. 73 41 W., 737.15 m., more or less, from
triangulation station, Baguio townsite; thence N. 56 15 W., 12.09 m.
to point 2; thence N. 62 58 W., 17.92 m. to point 3; thence N.
70 58 W., 17.91 m. to point 4; thence N. 78 58 W., 17.91 m. to
point 5; thence N. 86 58 W., 17.91 m. to point 6; thence S. 85
02 W., 10.00 m. to point 7; thence N. 50 15 E., 40.87 m. to point
8; thence S. 59 44 E., 218.25 m. to point 9; thence N. 65 22 E.
90.52 m. to point 10; thence S. 14 24 W., 32.07 m. to point 11;
thence S. 83 01 W., 2.67 m. to point 12; thence S. 80 01 W.,
39.40 m. to point 13; thence S. 83 10 W., 17.82 m. to point 14;

thence N. 89 34 W., 22.09 m. to point 15; thence N. 81 34 W.,

53.22 m. to the point of beginning; containing an area of five
thousand two hundred ninety-five (5,295) square meters, more or
less. All points referred to are indicated on the plan; and on the
ground, points 1, 3, 5, 7, 11, 13, 15, 17, and 19
are marked by old concrete monuments; and the rest, by B. L.
concrete monuments; bearings true; declination, 1 30 E., date of
the subdivision survey; during 1911 to 1912. as evidenced by a map
delineated by the Baguio Water District (BAWADI) herein attached
as ANNEX A;
(4)That the watershed is one of the major source of water of
(BAWADI) Baguio Water District which supplies potable water for
the whole area of Baguio City as evidenced by a certification from
BAWADI herein attached as ANNEX B;
(5) That the defendants are the owners of the concrete structures
built within the area covered by the camp 8 watershed as evidenced
by photographs herein attached as ANNEX C;
(6) That defendants engage into prohibited activities like
kaingin/farming/ garnening, garbage dumping within the enclosed
area covered by Camp8 watershed as evidenced by photographs
herein attached as ANNEX D;
(7)That the continuous illegal activities will substantially destroy and
endanger the watershed and the environment which will deprive the
entire people of Baguio City of the right to a healthy and balance
ecology;
(8)By reason of defendants unwarranted activities the supply of
potable water for Baguio City is imperil;
WHEREFORE, plaintiff respectfully prays for judgment to be
rendered in his favor through a decision directing defendants to
demolish illegal structures and to stop illegal activities of kaingin,
illegal logging and illegal garbage dumping.
Other legal and equitable reliefs are likewise prayed for.
This 17th day of november2014, in the4 City of Baguio Philippines

ATTY: KMU, IYAMAN

Counsel for Defendant

3rd Floor, Jupiter Bldg., Bonifacio St,. Baguio City

PTR No. 20345; 01/02/2014; Baguio City
IBP OR No: 1907772; 01/02/2014; Baguio City
Roll No.: IV-69302; 05/08/2004
MCLE Compliance No.: 34321; 04/25/2013
Baguio City, Philippines
TIN No. 196-023-114
This is a sample draft for academic purposes. Annexes will be
supplied when BAWADI gives the required documents.
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