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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 attorneys 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
Attorneys 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 13 th 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

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