REPUBLIC OF THE PHILIPPINES JUDICIAL REGION COURT OF FIRST INSTANCE BRANCH XIV, LAGUNA REGINO RELOVA AND TEODULA

BARTOLOME, Plaintiffs, -versusTRANQUILINO CALO AND DOROTEO SAN JOSE, Defendants. x-------------------------------------------x COMPLAINT Plaintiff, by counsel, unto this Honorable Court, respectfully states that: 1. The plaintiffs and defendants are all of legal age, Filipino citizens, and residents of Pila, Laguna; the plaintiffs as husband and wife; 2. The plaintiff spouses are the owners and the possessors of the land in controversy; 3. That parcel no. 123 is now an unplanted rice land and parcel no. 456 is a coconut land both under the possession of the plaintiffs; 4. The defendants, without any legal right or whatsoever and in connivance with each other through the use of force, stealth, threats and intimidation, intend or are intending to enter and work or harvest whatever existing fruits may now be found in the lands in violation of plaintiffs proprietary rights thereto; 5. Unless defendants are barred, restrained, enjoined, and prohibited from entering or harvesting the lands or working therein though ex parte injunction, the plaintiffs will suffer injustice, damages, and irreparable injury to their great prejudice; and 6. On or about June 26, 1945, the defendants, through force, destroyed and took away the madre-cacao fences and barbed wires built on the said lands. PRAYER WHEREFORE, it is respectfully prayed that: a. A writ of preliminary injunction be issued ex-parte immediately restraining, enjoining and prohibiting the defendants, their agents, servants, representatives, attorneys, and/or other persons acting for and in behalf, from entering in, interfering with and/or in any wise taking any participation in the harvest of the lands belonging to the plaintiffs; or in any wise working the lands above-described; b. Judgment be rendered, after due hearing, declaring the preliminary injunction final; and c. Defendants must be condemned jointly and severally to pay the plaintiffs the sum of P200.00 as damages. Plaintiff also prays for other relief, as may be deemed just or equitable by this Honorable Court. ATTY. ESTANISLAO FERNANDEZ Counsel for Plaintiff 456 MNO Street San Roque Subdivision Laguna

Civil Case No. 7951 For: Motion for Writ of Preliminary injunction

VERIFICATION AND CERTIFICATION We, Regino Relova and Teodula Bartolome, Filipino citizens, both of legal age, residing at Pila, Laguna, do hereby depose and say that: 1. We are the Plaintiffs in the case entitled Relova vs. Calo for writ of preliminary injunction filed within the Court of First Instance of Laguna, Branch XIV; 2. We caused the preparation and filing of this foregoing Complaint; 3. All the allegations stated in the above pleading were read and understood by us; 4. We did not commence any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or the different Divisions thereof, or any other tribunal or agency; 5. That shall we learn thereafter a similar action or proceeding has been filed or in pending before the Supreme Court, the Court of Appeals, or any other tribunal or agency, we undertake to report the fact within five days to this Court.

REGINO RELOVA and TEODULA BARTOLOME Affiants JURAT SUBSCRIBED AND SWORN to before me this 1st day of August 1945 at Laguna, Philippines, affiants who are personally known to me, exhibiting their Drivers License numbered 123-456 and 654-321 respectively, issued last August 1, 1944 at Laguna and their SSS ID numbered 987-654 and 456-789 respectively, issued last September 14, 1944 at Laguna City. Doc. No. 1; Page No. 2; Book No. III; Series of 1944. ATTY. ANGELA DE GRACIA NOTARY PUBLIC for Laguna City Until December 31, 1945 PTR NO. 12345678 159 AMZ Street St. Dominic Road Laguna Copies Furnished: CALO AND SAN JOSE Defendants 123 ABC Street San Pedro Village, Laguna ATTY. ZOSIMO TANALEGA Counsel for Defendants 654 ONM Street San Lazaro, Laguna