Republic of the Philippines )

City of Cebu ) S.S.

COMPLAINT – AFFIDAVIT

I, LUCIA A. TAN, of legal age, Filipino, single, with residence and

postal address at P. Remedios Street, Banilad, Mandaue City, after having
been duly sworn to in accordance with law do hereby depose and state,
that –

1. I am the complainant of this Ejectment case for forcible entry against

Lino G. Vasquez.

2. I know the person of Lino G. Vasquez as the owner of an adjoining lot

of the property in question in SRP and is currently living at #24 Il
Corso, SRP (South Road Properties), Cebu City where he may be
served with summons and other processes emanating from this
Honorable Court.

3. I become the owner of a certain parcel of land through the LAST

WILL AND TESTAMENT of my father, MR. LUCIO B. TAN. (A copy
of the Last Will and Testament is hereto attached as “Annex A”);

4. The parcel of land, situated in #23 Il Corso, SRP, Cebu City, is

covered by the Transfer Certificate of Title No. 12345 issued by the
Register of Deeds of Cebu City and is more particularly described, as
follows:

“A PARCEL OF LAND (Lot 23), situated in Il Corso, SRP, Cebu City

in the Island of Cebu. Bounded on the NE., points 3 to 6 by Lot 45; on
the S., points 6 to 1 by Lot 24; on the SW points 1 to 2 by Lot 25; and
on the N., points 2 to 6 by Lot 22.”

(Copy of TCT – 12345 is hereto attached as “Annex B”);

5. Mr. Vasquez, through stealth and strategy, occupied and fenced the
parcel of land in question and refuses to vacate and/or remove the
fence and return the same despite repeated oral and written
demands. (Copy of the written demand is hereto attached as “Annex
C”);

6. I filed a complaint in Barangay Pardo, Cebu City for a compromise

agreement with Mr. Vasquez on March 1, 2017 but we did not reach
an agreement, hence this complaint. (Copy of Barangay Certification
to File an Action is hereto attached as “Annex D”);
7. This prompted me to file this affidavit to support my complaint against
the respondent for Forcible Entry and for whatever legal purpose that
this may serve.

8. I also pray for damages consisting of attorney’s fees in the amount of

Thirty Thousand Pesos (P30,000.00) and filing fee, cost of
transportation and other miscellaneous accommodation of my
lawyers and other personal expenses to be incurred in attending the
hearings of this case in the amount of TEN THOUSAND PESOS
(P10,000.00);

9. This action is governed by the Rules on Summary Procedures.

IN WITNESS WHEREOF, I hereby set my hand this 24th day of

March, 2017 in Cebu City, Philippines.

LUCIA A. TAN
Plaintiff
SSS ID No. 1-123456-7

SUBSCRIBED AND SWORN TO before me, a Notary Public, on 24th

day of March, 2017 in the City of Cebu, affiant showing his official
identification document as stated above.

I also hereby certify that I have personally examined the affidavit and
that I am convinced that he voluntarily executed the foregoing affidavit
and that he understood the contents thereof.

WITNESS MY HAND AND SEAL.

Notary Public
Doc. No. ____
Page No. ____
Book No. ____
Series of 2017