Professional Documents
Culture Documents
Branch 21
Tarlac City
JUANA CHANGE
Plaintiff
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COMES NOW PLAINTIFF, JUANA CHANGE, thru counsel, unto this Honorable
THE PARTIES
1. That plaintiff, Juana Change plaintiff is of age, and a resident of Tarlac City
where she may be served with summons and other processes of this
Honorable Court.
2. That defendant, Miguel Guel is is also of age, with residence and post office
address at 14344 Tarlac City, where he may also be served with summons,
1. That the plaintiff is the absolute owner of that property located at Sto. Cristo,
Tarlac City, as stated in Transfer Certificate of Title No. 12345 as per legal
2. That plaintiff has been deprived of her right to use, enjoy and possess the
the defendant
3. That the plaintiff has twice demanded for the defendant to vacate the
4. That due to the unlawful occupation of the defendant the plaintiff has suffered
(Php 20,000.00), due to evident bad faith of the defendant; defendant should
also pay One Hundred Fifty Thousand Pesos (Php 100,00.00) in back lease
or rentals for the past seven (1) year of his unlawful possession and
Pesos (Php 50,000.00) in attorneys fees and the costs of this suit.
he will pay the tax dues on the property amounting to Five Hundred
and that he vacates the premises and surrenders the possession and
immediately.
a. That Juana Change the true and lawful owner of the property
ISSUES
DOCUMENTARY EXHIBITS
APPLICABLE LAWS
The Revised Rules of Court and the Civil Code of the Philippines.
Respectfully submitted.
PTR No.070613
Victoria, Tarlac
Copy furnished:
ATTY. -----------------------------------
Counsel for the Plaintiff
Unit 1234 Laurel Building
Pampanga
EXPLANATION
Service of copy to the Defendant and his counsel were done by registered mail
due to lack of manpower to effect personal service.
(Signed)
Atty. _________________