Jose Yao offered to sell his piece of land located in Bagumbayan to Rodrigo Go in the amount of

P1,000,000.00. On January 2017, Rodrigo agreed to buy the land and tendered an earnest
money on January 20 in the amount of P250,000.00 which was accepted by Jose. According to
Rodrigo, he will tender the balance money of P250,000.00 on July 21, 2017. Comes July 2017,
Rodrigo tendered the other half but Jose refused to get the other half and told Rodrigo that he
was no longer selling the land to Rodrigo because Jose has found another buyer was refused
who will buy the land for P2,000,000.00.

Prepare the necessary complaint. Attach the problem to the complaint.

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
FIFTH JUDICIAL REGION
 NAGA CITY, CAMARINES SUR
BRANCH 19

Rodrigo Go, CIVIL CASE NO. 12345

Plaintiff, FOR:
SPECIFICPERFORMANCE
versus.
Jose Yao,
Defendant.
X-----------------------------------------X

COMPLAINT

COMES NOW, Plaintiff Rodrigo Go, through counsel, to this Honorable Court, most
respectfully states that:;

1. Plaintiff, Rodrigo Go, is of legal age, married, Filipino citizen and a resident of
1234 ABC Avenue Concepcion Grande , Naga City where he may be served
with summons and other court processes;
2. Defendant, Jose Yao, is likewise of legal age, married, Filipino citizen and a
resident of 5678 ABC Avenue Bagumbayan , Naga City where he may be
served with summons and other court processes;
3. That defendant Jose Yao offered to plaintiff Rodrigo Go the former's piece of
land located in lot 3, Bagumbayan Norte, Naga City in the amount of
P1,000,000.00.
4. That on or about January 2017, Rodrigo and Jose entered into an agreement
in which Jose agreed to sell his piece of land located in Bagumbayan, Naga
City in the sum of P1,000,000.00.
5. That on January 20, 2017, Rodrigo agreed to buy the land and tendered an
earnest money in the amount of Two Hundred Fifty Thousand Pesos
(P250,000.00).
6. That Rodrigo promised to tender the balance money of Two Hundred Fifty
Thousand Pesos(P250,000.00) on July 21, 2017.
7. Comes July 2017, Rodrigo tendered another half of the balance money to Jose
but Jose refused to get the other half and told Rodrigo that he was no longer
 selling the land to him because Jose has found another buyer who will buy the
land for P2,000,000.00.
8. That due to the unjust and unlawful act of the defendant Jose Yao plaintiff
Rodrigo Go was compelled to institute this action engaging the services of the
undersigned counsel in the amount of P20,000.

PRAYER

IN LIGHT OF THE FOREGOING, it is most respectfully prayed of this Honorable Court that
after due notice and hearing, judgment be rendered in favor of Plaintiff and against
defendant ordering the latter, as follows:

1. For an order that defendant, Jose Yao, specifically perform the agreement and deliver the
real property to plaintiff, Rodrigo Go.

2. To pay moral damages in an amount determined by the court to be reasonable as authorized

by agreement and according to proof;

3. To pay attorney's fees in an amount determined by the court to be reasonable as authorized

by agreement and according to proof;

4. To pay exemplary damages in the amount determined by the court to be reasonable as

authorized by agreement and according to proof;

5. To pay cost of the suit.

Other relief and remedies that are just and equitable under the premises are likewise prayed
for.

Naga City, Philippines. July 30, 2017

Atty. German Lucena

Counsel for the Plaintiff

2ND Floor Alminos Bldg., corner Ed

Sheeran, Maligaya St., Zone VI, Isarog Avenue,

Naga City. PTR NO. 9876543/Isarog Avenue,Naga

City

IBP NO. 123789 Naga Chapter

Attorneys Roll No. 09876

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

 I, Rodrigo Go, of legal age, married, Filipino and the plaintiff in the above entitled case,
after being duly sworn to in accordance with law do hereby depose and say;

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

2. That I caused the preparation of the complaint and I read the allegations contained
therein and understood each of them to be true and correct of my own personal
knowledge and beliefs and based on authentic documents.
3. That I further certify that I have not commenced any action or proceeding involving
the same issues in the Supreme Court, the Court of Appeals or different divisions
thereof, or any court, tribunal or agency.
4. That should I learn hereafter of the filing or pendency of such action/s, I undertake
to inform this Honorable Court of said fact within five (5) days from knowledge
therefrom.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 30th day of July, 2017
at Naga City, Philippines.

Rodrigo Go

Plaintiff

SUBSCRIBED AND SWORN TO BEFORE ME, this 30th of July, 2017 at Naga City,
Philippines.

Atty. Tristan Clarkson

Ser. No.04-1234
Notary Public until December 31, 2018
Roll no.1111
PTR no. 8899 / Naga City / 05/13/18
IBP no. 5690 / Naga City / 12/15/18
MCLE no. 567890

Doc. no. 21
Page no. 4
Book no. 7
Series of 2017