Republic of the Philipppines

REGIONAL TRIAL COURT

Branch ___, Makati City

Republic of the Philippines,

Plaintiff,

-versus - Civil Case No.

Juan dela Cruz,

Defendant.

x x

COMPLAINT FOR REVERSION

(For Violation of Public Land Act)

PLAINTIFF, by the undersigned Solicitor General, and alleges:

1. Plaintiff is legal entity created by the Constitution, with the power to sue, through the Solicitor
General as provided by law.

2. Defendant applied for a homestead of a piece of land, consisting of five (5) hectares in barrio
______, Municipality of _______, Province of _______, claiming among others that he took
possession of the land and cultivated it for _____years, and after investigation by the officers of the
Bureau of Land Management, the latter recommended approval of the application for homestead
patent, and was eventually issued Patent No. _____, which defendant registered with the Registry of
Deeds for _____ and was issued a certificate of title covering the land.

3. The Bureau of Land Management subsequently made a land mapping and survey of public lands in
said barrio of ____, Municipality of _____, Province of ______, and officers thereof found that the
parcel of land applied for homestead by defendant still formed part of the timber land and had not
been reclassified as alienable and disposable.

4. The patent issued to defendant is accordingly null and void as violative of the Public Land Act, as it
covered lands which are prohibited from being alienated and disposed and as it formed and still
forms part of the timber lands of the public domain.

WHEREFORE, plaintiff prays that the homestead patent granted to defendant be declared null and
void and that same be reverted back to the public domain.

Place and date.

 Solicitor General
Counsel for Plaintiff
Address: _______
Roll No.:________
IBP No._____, issued
On_______at______
PTR No. ____issued
On ______at _____.

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

(To be accomplished or executed by the Director of the Land Management Bureau.)

I, _____, of legal age and with residence at 50 Maria Clara, Makati City, after having duly sworn, depose
and say:

1. That I am the plaintiff/petitioner in the above-entitled complaint/petition.

2. That I caused the preparation of said complaint/petition.

3. That I have read the allegations therein contained, and that the same are true and correct of my
personal knowledge or based on authentic records.

4. That I have not theretofore commenced any action or filed any claim involving the same issues in any
court, tribunal, or quasi-judicial agency and, to the best of my knowledge, no such other action or
claim is pending therein; and if I should thereafter learn that the same or similar action or claim has
been filed or is pending, I shall report that fact within five (5) days therefrom to the court wherein
the aforesaid complaint or initiatory pleading has been filed.

Witness my hand this _____ day of ____20___ at Makati City, Philippines.

Affiant

SUBSCRIBED AND SWORN to before me, a notary public in and for _____, this day of ____, at
_____, Philippines, affiant appearing before me with his ID No. ______issued on _____at______and
presenting to me a document entitled ____________, affiant being known to me personally and who
signed said document in my presence and sworn as to said document that he understood the contents
thereof and that the same was his free and voluntary act and deed.

Notary Public
Until Dec. 31, 20_
Doc No.
Page No.
Book No.
Series of 20__.
 Republic of the Philipppines
REGIONAL TRIAL COURT
Branch ___, Makati City

Republic of the Philippines,

Plaintiff,

-versus - Civil Case No.

Juan dela Cruz,

Defendant.

x x

COMPLAINT FOR REVERSION

(For Violation of Constitutional Restriction)

PLAINTIFF, Republic of the Philippines, by the Solicitor General, respectfully alleges:

1. Plaintiff is legal entity created by the Constitution, with the power to sue, through the Solicitor
General as provided by law.

2. Defendants _______and _____are both of legal age and with residence at ______and with residence
at _____and ______, respectively.

3. On____, defendant Juan dela Cruz, a Filipino, sold his residential land consisting of 1,000 sq.m. with
TCT No. ____ and situated in Makati City, in favor of defendant Pedro San Juan, for P3,000,000.00,
the buyer claiming to be a Filipino citizen, pursuant and to which the buyer was issued a new
certificate of title, TCT No. ____, of the Registry of Deed for Makati City.

4. Investigations revealed that defendant Pedro San Juan was actually a Chinese citizen, born in
mainland China on _____ and was smuggled to the Philippines at the time he bought the parcel of
land and remains a Chinese citizen even up to present.

5. The sale of the parcel of land in favor of defendant Pedro San Juan was null and void, as he was
disqualified by the Constitution to own and acquire lands in the Philippines.

WHEREFORE, plaintiff prays that the sale of the land to defendant Pedro San Juan and the TCT ____
issued to him be declared null and void, and the land reverted back to the State, as his acquisition
was in violation of the Constitution.

Place and date.

 Solicitor General
Counsel for Plaintiff
Address: _______
Roll No.:________
IBP No._____, issued
On_______at______
PTR No. ____issued
On ______at _____.

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, _____, of legal age and with residence at 50 Maria Clara, Makati City, after having duly sworn, depose
and say:

6. That I am the plaintiff/petitioner in the above-entitled complaint/petition.

7. That I caused the preparation of said complaint/petition.

8. That I have read the allegations therein contained, and that the same are true and correct of my
personal knowledge or based on authentic records.

9. That I have not theretofore commenced any action or filed any claim involving the same issues in any
court, tribunal, or quasi-judicial agency and, to the best of my knowledge, no such other action or
claim is pending therein; and if I should thereafter learn that the same or similar action or claim has
been filed or is pending, I shall report that fact within five (5) days therefrom to the court wherein
the aforesaid complaint or initiatory pleading has been filed.

Witness my hand this _____ day of ____20___ at Makati City, Philippines.

Affiant

SUBSCRIBED AND SWORN to before me, a notary public in and for _____, this day of ____, at
_____, Philippines, affiant appearing before me with his ID No. ______issued on _____at______and
presenting to me a document entitled ____________, affiant being known to me personally and who
signed said document in my presence and sworn as to said document that he understood the contents
thereof and that the same was his free and voluntary act and deed.

Notary Public
Until Dec. 31, 20_
Doc No.
Page No.
Book No.
Series of 20__.