Republic of the Philippines

Regional Trial Court

Ninth Judicial Region
Branch 2
Zamboanga City
BRUNO TAN
Plaintiff,

CIVIL CASE NO. 2314

FOR
-versusRECONVEYANCE OF
TITLE
CHINA-ARAB BANK OF THE PHILIPPINES ZAMBOANGA BRANCH AND ALBERTO TAN
Defendants
x--------------------------------------x
COMPLAINT
COMES NOW, the Plaintiff, BRUNO TAN, through the undersigned
counsel and unto the Honorable Court most respectfully avers that:
1. Plaintiff is a Filipino Citizen, of legal age, single and a resident of

123-A, Jupiter Road, San Ramon, Zamboanga City, where he may be

served with summons and other processes of the Honorable Court;
2. China-Arab Bank of the Philippines, herein Defendant, is a banking

institution duly organized and incoporated under Filipino laws,

registered with the Banko Sentral ng Pilipinas, with the branch
address at 1234-B, Nunez-Brillantes Road, Zone VIII, Zamboanga
City;
3. Alberto Tan, also herein Defendant, is a Filipino, of legal age, single

and a resident of No. 793 Bonificia Street, Sinunuc, Zamboanga City

where he may be served with summons and other processes of this
Honorable Court;
4. The Plaintiff, Alberto Tan and their siblings, namely, Cynthia Tan, Des

Tan and Elaine Tan, maintained savings account with the China-Arab
Bank. Attached are the certification of the bank.
5. The Plaintiff his siblings inherited a parcel of land from their father,

Ngu Tan through testate succession, the land is described as follows:

DETAILS OF THE LAND
6. On December 1, 2008 or three months after the receipt of the land, the

siblings divided the land in equal shares and were issued titles to the
land, attached is the subdivision plan and titles;

7. On January 18, 2009, the Plaintiff left to work in the United States of

America as an operating room nurse Certification, Contract of

Employment. He left the owner's duplicate of the land with his older
brother, Alberto Tan;
8. On September 2, 2009, while the Plaintiff was still abroad

(certificate), a deed of sale was executed wherein the plaintiff's lot

was sold to Alberto Tan (deed of sale);
9. The following day or on September 3, 2009, Alberto Tan applied for a

secured loan with the bank (application form),the loan was released
on September 10, 2009 and the lot was mortgaged (mortgage) (loan
agreement with that clause);
10. On March 16, 2012, the bank foreclosed the lot due to non-payment of

Alberto Tan of the loan (cancellation of title) (foreclosure sale) (new

title) (everything else)
11. On June 15, 2013, the Plaintiff went back to the Philippines and to his

surprise the property was already owned by the bank.

12. Hence, the Plaintiff is compelled to file the instant action for

cancellation of the old title and reconveyance of the new oen....