Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
QUEZON CITY
Branch 031

JUAN AYSION SANTOS

Plaintiff,

-versus- CIVIL CASE No. Q-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 od 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 attorneys 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 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 (P30,000.00) by way
of attorneys fees and Twenty Five Thousand Pesos (P25,000.00), 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, 2011. Quezon City, Metro Manila.

ATTY. PHOEMELA G. CRUZ

Counsel for Plaintiff
Quezon City
Roll of Attorneys No. 1234567
IBP No. A-1234567
PTR No. A- 1234567
MCLE No. A-1234567
 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 1 st day of

May 2012, City of Quezon, Metro Manila, Philippines.

JUAN AYSION SANTOS

Affiant
CTC No. 1234565
Issued On: May 4, 2011
Issued At: Quezon City

SUBSCRIBED AND SWORN to before me, in the City of Quezon, this

1st day of May 2012, City of Quezon, Metro Manila, Philippines, affiant having ex
habited to me his Drivers License No. ___________, issued at Quezon City,
Philippines.

ATTY. DAN B. SAN

Notary Public
Until December 31, 2013
PTR No. A-123056
Issued at Quezon City
On January 1, 2012

Doc. No. 1;
Page No. 1;
Book No. 1;
Series 2012.