Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch _____, Pasig City

VINCENT V. LAUENGCO,
Plaintiff,

- versus - Civil Case No. __________

For: REVINDICATION
JANICE COSME LAUENGCO and
ETON PROPERTIES PHILIPPINES, INC.
(EPPI),
Defendants.
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COMPLAINT

COMES NOW Plaintiff, by himself, unto this Honorable Court,

most respectfully states and avers that:

1. Plaintiff is of legal age, Filipino, and a resident of No. 47

Severina Ave., Km. 18, Parañaque City;

2. Defendant Janice Cosme Lauengco is the legitimate daughter

of Pio Martin Lauengco and half-sister of herein Plaintiff, residing at

1133, Craig St., Sampaloc, Manila, where she may be served with

summons and other court processes;

3. Defendant Eton Properties Philippines, Inc., (EPPI) is a

corporation with office address at 12 th Floor, Allied Bank Bldg., Ayala

Avenue, Makati City;

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4. Plaintiff is the illegitimate son of Pio Martin T. Lauengco as

evidenced by herein Certificate of Live Birth with Affidavit of

Acknowledgment marked as Annexes “A” and “A-1”;

5. Pio Martin T. Lauengco died on Nov. 02, 2007 as evidenced by

herein Certificate of Death marked as Annex “B”;

6. Immediately after the death of their father, or on November

13 2007, defendant Janice Cosme Lauengco executed an Extrajudicial

Settlement of Estate Among Heirs of Pio Martin T. Lauengco. The said

Extrajudicial Settlement of Estate was executed without the knowledge

and consent of herein Plaintiff and was tainted with fraud, defendant

knowing fully well that she was not the only heir of Pio Martin T.

Lauengco;

7. On November 29, 2007, Janice Lauengco then executed a

document entitled “RELEASE, WAIVER, AND QUITCLAIM WITH

UNDERTAKING (Marked as Annex “C”) in favor of defendant Eton

Properties, Inc. (EPPI), claiming therein that she is the sole heir of the

late Pio Martin T. Lauengco. In the said document, defendant Lauengco

acknowledged that she had received the amount of TWO HUNDRED FIVE

THOUSAND NINE HUNDRED THIRTY PESOS AND THIRTY TWO

CENTAVOS (PHP 205,930.32). Defendant Janice Lauengco appropriated

the said amount all to herself without giving the Plaintiff his rightful

share;

8. Plaintiff and Plaintiff’s mother, Corazon A. Valiente,

repeatedly demanded from Janice Lauengco the amount corresponding

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to Plaintiff’s share in the EPPI, but to no avail. Plaintiff then requested

defendant EPPI that he (Plaintiff) be given his rightful share in the

remaining receivables/sales commissions his deceased father is entitled

but then again, defendant EPPI refused to acknowledged Plaintiff as a

rightful claimant;

9. By reason of the unjustifiable refusal of defendant Janice

Lauengco to give unto Plaintiff Vincent Lauengco his rightful share in the

properties left by their deceased father, defendant Janice Lauengco

should be held liable to pay Plaintiff the amount of Sixty Eight Thousand

Six Hundred Forty Three and Forty Four Centavos (Php 68,643.44)

corresponding to Plaintiff’s share on the EPPI’s Sales Commission of their

deceased father amounting to P205,930.32;

10. Defendant Janice Lauengco should also give unto Plaintiff

his rightful share on the condominium left by their deceased father

registered under Condominium Certificate Title No. 13991 which is still

existing;

11. For refusing to release the remaining EPPI sales commission

of their deceased father to herein Plaintiff, EPPI should be ordered to

hold in abeyance whatever amount Pio Martin T. Lauengco is entitled

and be restrained from releasing it to any claimant, especially to

defendant Janice C. Lauengco.

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PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the

Honorable Court that judgment be rendered in favor of the Plaintiff and

against the defendants as follows:

1. ORDERING Defendant Janice Cosme Lauengco to pay

Plaintiff the amount of Sixty Eight Thousand Six
Hundred Forty Three and Forty Four Centavos (Php
68,643.44) corresponding to Plaintiff’s share on the
EPPI’s Sales Commission of their deceased father
amounting to P205,930.32;

2. ORDERING Defendant Janice Cosme Lauengco to give

unto Plaintiff his rightful share on the value of the
condominium left by their deceased father registered
under Condominium Certificate Title No. 13991 which is
still existing;

3. ORDERING Defendant EPPI to hold in abeyance

whatever amount Pio Martin T. Lauengco is entitled as
his Sales Commission in EPPI and be retrained from
further releasing it to any claimant, especially to
defendant Janice C. Lauengco, until ordered by the
Honorable Court.

Other reliefs just and equitable under the premises are likewise

prayed for.

Makati City, this ____ day of January 2011.

VINCENT V. LAUENGCO