i.

a temporary restraining order (TRO) be issued ex-parte,

enjoining the defendants, and any person acting for and
on their behalf, from occupying and fencing the
perimeter of the subject lot and for planting trees or any
kind of improvements thereon; and,

ii. after due proceedings, extend the 72-hour TRO to 20

days, and after hearing, issue a writ of preliminary
injunction;

(a) After trial on the merit:

i. issue a writ of permanent injunction by perpetually

enjoining the defendants, and any person acting for and
on their behalf, from occupying and fencing the
perimeter of the subject lot and for planting trees or any
kind improvements thereon;

ii. declare as null and void the Deed of Sale dated

December 31, 2011 purportedly executed by defendants
Spouses Pedro (a.k.a. “Nabbun”) Guinanoy and Avelina
Guinanoy in favor of defendant Estela Dulnuan, married
to defendant Ambrocio Dulnuan, over a portion of One
thousand nine hundred (1,900) square meters of the lot
owned by plaintiff;

iii. declare herein plaintiff as rightful owner of the subject

lot and order the defendants and any person acting for
and in their behalf to respect her possession and
ownership thereof,

iv. directing the defendants to pay, jointly and severally, the

following sums of money to plaintiff: Fifty thousand
pesos (P50,000.00) as moral damages; Twenty five
thousand pesos (P25,000.00) as exemplary damages;
Twenty thousand pesos (P20,000.00) as attorney’s fees
plus appearance fee of Two thousand five hundred pesos
(P2,500.00) per hearing; and, the cost of suit.

Other reliefs just and warranted under the premises are also prayed for.