Professional Documents
Culture Documents
COMPLAINT
PLAINTIFFS, through counsel and before the Honorable
Court, most respectfully state that:
THE PARTIES
in
Barangay
Pinagsabangan,
Naujan,
Oriental
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assessed
value
of
photocopy
of
Plaintiff
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Regina
Ramos
Transfer
Certificate
of
Title
(TCT)
No.
064-
Transfer
Certificate
of
Title
(TCT)
No.
064-
Transfer
Certificate
of
Title
(TCT)
No.
064-
son
Daniel
S.
Ramos
under
TCT
No.
064-
2014001627, declared under Tax Declaration No. 2012-0805100292. A photocopy of Plaintiff Nestora Ramos CANCELLED
Certificate of Title is appended herewith as Annexes N, N-1, N2 and N-3; and a photocopy of the new TCT in the name of
Daniel S. Ramos is appended herewith as Annexes O, O-1
and O-2. Photocopies of the Tax Declarations of aforesaid
properties are appended herewith as Annexes P, P-1, P-2, P3, P-4, P-5, P-6 and P-7.
17) To avoid litigation, Plaintiffs exerted earnest efforts to
settle
the
matter
with
the
Defendants
through
verbal
These
factual
events
fraudulently
dispossessed
In Sevilla
vs. De
los
Angeles (97
Phil.
875
the
ground
of
fraud
and
the
proper
remedy
is
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THE RELIEFS
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WHEREFORE,
premises
considered,
it
is
most
Nos.
064-2014001626,
064-2014001624,
064-
064-2012005607,
064-2012005606,
064-
2012005610;
4) ORDERING defendants to jointly and severally pay
plaintiffs:
a) PhP20,000.00 as and for attorneys fees;
e) Cost of suit.
Quezon
City
for
Calapan
City,
Oriental
Mindoro,
RIO T. ESPIRITU
Counsel for Plaintiffs
48-C Malakas St., Brgy. Pinyahan
Quezon City
Roll of Attorney No. 34988
PTR No. 9120190, 01/09/14, Q.C.
IBP No. 925983, 01/15/14, Q.C.
MCLE No. IV - 0016174 April 10, 2013
If I should
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NOTARY PUBLIC
Until 31 Dec. 2014.
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