Republic of the Philippines

REGIONA TRIAL COURT

Tuguegarao City
Second Judicial Region
Tuguegarao City, Cagayan

JOHN A. JUAN
Plaintiff, CIVIL CASE NO.___________

- versus – FOR: ANNULMENT OF TITLE

JAIME B. TUO
Defendant.

COMPLAINT
1. Plaintiff is of legal age, Filipino Citizen and residing at Casablanca Cagayan where he

may be served with orders, notices and other processes issued by the Honorable Court.

2. Defendant Jaime B. Tuo, is also of legal age, Filipino citizen, is a resident of Bayo,

Iguig Cagayan, where he may be served with summons and other court processes;

3. That Plaintiff is the registered and lawful owner of a parcel of land located at

Casablanca Cagayan covered under Transfer Certificate of Title No. T-12345, and

more particularly described as follows:

“… A parcel of land Lot No. 1578 of the Casablanca Public Lands Subdivision, Pls-62,

Cadastral Case No. N-2 LRC Cadastral Redords No. N-16 with the improvements

thereon situated in the Casablanca, Province of Cagayan. Bounded on the NE., points

1-2 by Lot 1577; on the NW., points 2-3, by lot 1576; on the NE., points 3-4, by Road;

and on the SE., points 4-1, by Lot 1579. Containing an area of SEVEN HUNDRED

AND FIFTY ONE (751) square meters, more or less…”

Attached herewith is a certified true copy of the TCT No. T-12345 and made an integral

part of this complaint;

 4. That herein Defendant, acting fraudulently and under false pretenses sold the lot, to a

certain Four Dy.

5. That because of the fraudulent acts and false pretenses of the defendant, Katibayan ng

Orihinal na Titulo Blg. P-78913 was generated to the prejudice of John Juan

6. That the Title of the defendants have arisen from fraud, false pretenses and

misrepresentation and must necessarily be cancelled and voided and that the title of the

plaintiff be declared as the lawful and valid one;

7. That to cite the defendant as an example for good of the public and to forestall other

individuals from acting in a similar manner, exemplary damages at no less than

P30,000.00 must be awarded to the plaintiffs;

8. That to aid plaintiffs in the recovery of the property, they have been compelled to

secure the services of counsel whose fees are agreed upon in the amount of

P50,000.00.

PRAYER

WHEREFORE, it is respectfully prayed of this Honorable Court, after due trial that judgment be
rendered ordering:

1. The cancellation of Katibayan ng Orihinal na Titulo Blg. P-78913 in the name of Jaime Tuo
2. That Transfer Certificate of Title No. T-12345 in the name of John Juan to be the lawful and
valid one;
3. The defendant to pay moral damages in the amount of P30,000.00;
4. The defendant to pay exemplary damages in the amount of P30,000.00; and
5. The defendant to pay P50,000.00 as and by way attorney’s fees.
Plaintiffs further pray for such other reliefs which are just and equitable under the premises.

Tuguegarao City, Cagayan- December 13, 2014

ATTY. KIMBERLEY DELA CRUZ- MATAMMU

Carig Sur, Tuguegarao City
Attorney’s Roll No. 54654
IBP No. 927307, Cagayan 1-2913
PTR No.3202399, Tuguegarao City, Cagayan, 1-21-13
MCLE Compliance No. 1110016263, 05-31-10
 VERIFICATION/CERTIFICATION

I, JOHN A. JUAN, of legal age, Filipino Citizen and residing at Baculud Iguig, Cagayan after
first having duly sworn to in accordance with law depose and say:

1. I am the plaintiff in the above- entitled case

2. I have caused the preparation of the foregoing complaint

3. The contents therein are true and correct to the best of my personal knowledge
and based on authentic documents.

4. I hereby certify that I have not commenced any action or proceeding involving the
same issue in any tribunal or agency, to the best of my own knowledge, no such
action or proceeding is pending in any other tribunal or agency and should I
thereafter learn that a similar action or proceeding has been filed or is pending in
Court, I will undertake to report such fact within five (5) days therefrom to the
court wherein this Petition and this certification have been filed.

IN WITNESS WHEREOF, I hve hereunto affixed my signature this 13th day of

December 2014 in Tuguegarao City, Cagayan Philippines.

JOHN A. JUAN
Affiant

SUBSCRIBED AND SWORN to before me this 13th day of December 2014 in

Tuguegarao City, Cagayn\an, Philippines

Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT

 QUEZON CITY

Branch 31

JUAN AYSION SANTOS

Plaintiff,

-versus- CIVIL CASE No. 16-12345

For: EJECTMENT (FORCIBLE ENTRY)

JOHN CHIU CO

Defendant.

x - - - - - - - - - - - - - - - - - - - - - - - - - - -x

COMPLAINT

PLAINTIFF, through the undersigned counsel, and unto this Honorable Court most respectfully
submits this Complaint for Forcible Entry and in support hereof makes the following assertions:

1. Plaintiff JUAN AYSION SANTOS, is residing at #123 Narra St., Fairville, Quezon City, where he
may be served with court order and other processes;

2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville, Quezon City where he may
be served with summons, order and other court processes;

3. Plaintiff became owner of a certain parcel of land, through a Deed of Sale from the original
owner, JANICE DY LEE. (A copy of the Deed of Sale is hereto attached as Annex “A”);
 4. The parcel of land, situated in #129 Fairville, Barangay Pangsy, Quezon City, is covered by
Transfer of Certificate of Title No. 12345 issued by the Register of Deeds of Quezon City and is
more particularly described, as follows:

(Description)

(Copy of TCT- 12345 is hereto attached as ANNEX “B”);

5. Herein Defendant, through stealth and strategy, occupied the parcel of land in question and
refuses to vacate the same despite repeated oral and written demands. (Copy of the written
demand is hereto attached as Annex “C”);

6. The same acts of the Defendant compelled the Plaintiff to incur damages consisting of
attorney’s fees in the amount of Thirty thousand pesos (P30,000.00) pesos and filing fee, cost
of transportation and other miscellaneous accommodation of its lawyers and other personal
expenses to be incurred in attending the hearings of this case in the amount of FIFTY
THOUSAND PESOS (Php 50,000.00).

7. This action is governed by the Rules on Summary Procedure;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court that, after
the proceedings, judgment be rendered in favor of the Plaintiff and ordering the Defendant and all
persons claiming rights under him to:

(a) Permanently VACATE the premises in question and give the immediate right of possession to
the Plaintiff;

(b) Pay plaintiff the amount of Thirty Thousand Pesos (P30,000.00) by way of attorney’s fees and
Fifty Thousand Pesos (P50,000.00), by way of other litigation expenses; and,
 (c) Pay the cost of this suit.

Plaintiff prays for such other remedies and reliefs as may be deemed just and equitable under the
premises.

May 1, 2016. Quezon City, Metro Manila.

ATTY. MARIANNE ENDRIANO

Counsel for Plaintiff

Quezon City

Roll of Attorneys No. 1234567

IBP No. A-1234567

PTR No. A- 1234567

MCLE No. A-1234567

ATTY. RE CHARLES TUPAS

Counsel for Plaintiff

Quezon City

Roll of Attorneys No. 1234568

IBP No. A-1234568

PTR No. A- 1234568

MCLE No. A-1234568

ATTY. MARY ANNE CAÑETE

 Counsel for Plaintiff

Quezon City

Roll of Attorneys No. 1234569

IBP No. A-1234569

PTR No. A- 1234569

MCLE No. A-1234569

ATTY. MARY JO DECOLONGON

Counsel for Plaintiff

Quezon City

Roll of Attorneys No. 1234570

IBP No. A-1234570

PTR No. A- 1234570

MCLE No. A-1234570

VERIFICATION AND CERTIFICATION

AGAINST NON- FORUM SHOPPING

I, JUAN AYSION SANTOS, of legal age, after being duly sworn to in accordance with law, depose
and attest:

That I am the petitioner in the above-titled case; that I have caused the preparation of the
foregoing petition and understood the contents thereof, and I hereby declare that all the allegations
contained therein are true and correct according to my knowledge and belief.
 Furthermore, I hereby certify that I have not filed nor caused to be filed any other similar case
involving the same issues in the Supreme Court, Court of Appeals or any other tribunal or agency and
that, should there be any other such case/s that may have been filed, I hereby bind myself to inform
the Court of such fact within five (5) days from the discovery thereof.

IN WITNESS WHEREOF, I have hereunto set our hand this 1st day of May 2016, City of Quezon,
Metro Manila, Philippines.

JUAN AYSION SANTOS

Affiant
CTC No. 1234565
Issued On: October 4, 2015
Issued At: Quezon City

SUBSCRIBED AND SWORN to before me, in the City of Quezon, this 1st day of May 2016, City of
Quezon, Metro Manila, Philippines, affiant having ex habited to me his Drivers License No. F01-
200215674, issued at Quezon City, Philippines.

ATTY. DAN B. SAN

Notary Public

Until December 31, 2017

PTR No. A-123056

Issued at Quezon City

On January 1, 2015

Doc. No. 180;

Page No. 35;

Book No. 2;

Series 2016.