Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
QUEZON CITY
Branch 31
JUAN DELA CRUZ
Plaintiff,
-versus-

CIVIL CASE No. Q-12345

For: EJECTMENT (FORCIBLE ENTRY)

JANE DOE
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 DELA CRUZ, is residing at #123 Golden St., Gameville,
Quezon City, where he may be served with court order and other processes;
2. Defendant JANE DOE, is a resident of #098 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, JAIME SANTOS;
4. The parcel of land, situated in #129 Gameville, Quezon City, is covered by
Transfer of Certificate of Title No. 12345 issued by the Register of Deeds of
Quezon City;

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;
6. The same acts of the Defendant compelled the Plaintiff to incur damages
consisting of attorneys fees in the amount of Thirty Thousand Pesos (Php
30,000.00) and filing fee, cost of transportation and other miscellaneous
accommodation of its lawyer amounting to Twenty-Five Thousand Pesos
(Php 25,000.00);
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 (Php 30,000.00) by way
of attorneys fees and Twenty Five Thousand Pesos (Php 25,000.00), by way
of other litigation expenses; and
c. Pay the cost of this suit.
Plaintiff prays for such other remedies and relief as may be deemed just and
equitable under the premises.
September 21, 2016, Quezon City, Metro Manila.
ATTY. MIGUEL DELOS SANTOS
Counsel for Plaintiff
Quezon City
Roll of Attorneys No. 1234567
IBP No. A-1234567
PTR No. B-1234567
MCLE No. C-1234567

VERIFICATION AND CERTIFICATION

AGAINST NON-FORUM SHOPPING
I, JUAN DELA CRUZ, 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 21 st day of
September 2016, City of Quezon, Metro Manila, Philippines.
JUAN DELA CRUZ
Affiant
CTC No. 123456
Issued On: May 3, 2015
Issued At: Quezon City
SUBSCRIBED AND SWORN to before me, in the City of Quezon, this 21 st
day of September 2016, affiant having exhibited to me his Drivers License No.
12345, issued at Quezon City, Philippines.
ATTY. CARL CRUZ
Notary Public
Until December 31, 2016
PTR No. A-123456
IBP No. B-123456
Roll No. C-123456

Doc. No. 4;
Page No. 1;
Book No. 1;
Series of 2016;