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Republic of the Philippines

REGIONAL TRIAL COURT


7th Judicial Region
Branch UV
Cebu City

HANSEL R. JALALON,
Plaintiff

CIVIL CASE NO. P 1232-15-PG


For Preliminary Injunction with
Damages

- versus -

MARC REYES
Defendant
x-----------------------------------------x

COMPLAINT
PLAINTIFF, by counsel and to this Honorable Court respectfully
alleges:

1.

That the Plaintiff, HANSEL R. JALALON, is a Filipino


citizen, of legal age, single and a resident of Upper Level,
3rd Door Vailoces Apartment, Rahmann Street, Gorordo
Avenue Cebu City where she may be served with copies
of notices, orders and other papers of this Honorable
Court;

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PARTIES

That defendant, Marc Reyes, is a Filipino, of legal age,


single and a resident of Door 1 Ground Floor, T. Padilla
Street Cebu City where she may be served with copies of
notices, orders and other papers of this Honorable Court;

2.

FACTS OF THE CASE


3.

That the plaintiff is the defendant in a confiscation case


filed in the Department of Agrarian Reform:

4.

That the defendant herein, as head of the Confiscation


Bureau, has caused to be confiscated, three vans
belonging to the plaintiff herein, alleging such automobiles
to have been used in illegal logging activities;

5.

That the vans were only rented from the plaintiff, and that
the logs transported therein were all licensed and
permitted to be transported as evidenced by the permits
presented, hereunto attached as exhibit A;

6.

That plaintiff is entitled to the relief demanded and the


whole or part of such relief consists in restraining the
commission or continuance of the acts complained of,
either for a limited period or perpetually; or

7.

That the commission or continuance of some act


complained of during the litigation would probably work
injustice to the plaintiff since such rentals are the plaintiffs
only source of income;

8.

That the plaintiff hereby applies for a writ of preliminary


injunction to restrain the defendant from the act herein
complained of, and for this purpose hereby offers a bond
in such sum as this Honorable Court may fix.

PRAYER
WHEREFORE, it is respectfully prayed of this Honorable Court
to decide in favour of the plaintiff and decree the following:

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1. That after due notice and hearing, a preliminary injunction be


issued forthwith to restrain defendant from doing the act
herein complained of, namely confiscating the vans subject
of litigation;
2. That after trial, said injunction be made permanent, with
costs;

3. And such further orders that are just and equitable in the
premises that the court may find well deserved.

IN WITNESS WHEREOF, I have hereto have hereby set their


hands on the 5th day of June, 2015, in Cebu City, Cebu.

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ATTY. MARC GRETEL R. MADANGUIT


COUNSEL FOR PLAINTIFF
Ground Flr, 1st Dr, V. Villa Estrella Apartment,
Rahmann Ext., Gorordo Avenue, Cebu City
ROLL NO. 48511 / 24 Jan 2005
IBP Lifetime Roll No.: 816036/ 25 Jan 2005
MCLE Compliance No. III-0319 / 8 Aug 2010
PTR No. 1234 / Cebu City / 01-25-2005

VERIFICATION AND CERTIFICATION OF


NON-FORUM SHOPPING
I, HANSEL R. JALALON, of Legal age, single, Filipino Citizen
and a resident of Upper Level, 3 rd Door Vailoces Apartment,
Rahmann Street, Gorordo Avenue Cebu City, after being sworn
according to law, hereby depose and state that;
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are
true and correct of my personal knowledge and/or on the basis
of copies of documents and records in my possession;
4. I have not commenced any other action or proceeding involving
the same issues in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding
has been filed or is pending before the Supreme Court, the
Court of Appeals, or any other tribunal or agency, I undertake to
report that fact within five (5) days therefrom to this Honorable
Court.

HANSEL R. JALALON
Affiant

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SUBSCRIBED AND SWORN TO BEFORE ME, a notary public


in and for the Province of Cebu this 5th day of June 2015. Affiant
personally came and appeared with her Professional Regulations
Commission ID Number 128-957-320 issued by Professional
Regulations Commissions Office of the Province of Cebu on January
24, 2010 at Cebu City, bearing her photograph and signature, known
to me as the same person who personally signed this foregoing

instrument before me and avowed under the penalty of law to the


whole truth and contents of the said instrument.

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Doc. No. 321


Page No. 3
Book No. 567
Series of 2015

ATTY. JUAN ISMAEL DE LA CRUZ


Ground Flr, 1st Dr, Vailoces Apartment, Rahmann
Street, Gorordo Avenue, Cebu City
COMMISSION NO.: 1234-1234
NOTARY PUBLIC for Cebu City
UNTIL December 31, 2018
OFFICE: Big Bldg, Door 308, Cebu City
ROLL NO. 48511 / 24 Jan 2005
IBP Lifetime Roll No.: 816037/ 25 Jan 2005
MCLE COMPLIANCE No. III-004319 / 10 Aug 2018
TIN 128-957-329

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