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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 11, MUNTINLUPA CITY
Cool Ninja Corporation
Plaintiff,

Civil Case No. ________


For: Interpleader

- versus Macopa Gomez


and Juris Doctoris Manalo
Defendants.
x----------------------------------------------x

COMPLAINT
Plaintiff, COOL NINJA CORPORATION (Plaintiff), by counsel,
and unto this Honorable Court,most respectfully avers THAT:
PARTIES
1. Plaintiff is a corporation duly organized and existing under
and by virtue of the laws of the Philippines, with principal business
address at 7th floor, St. Maur Building, Muntinlupa City. It may be
served with the pleadings, motions, notices, orders and other
processes of this Honorable Court through counsel at the address
indicated below.
2. Defendants MACOPA GOMEZ and JURIS DOCTORIS
MANALO (Defendants) are both Filipino citizens, of legal age and
with residences at 7 Macopa St., Ayala Alabang, Muntinlupa City and
8 Don Manolo St. Muntinlupa City, repectively, where they may be
served with pleadings, motions, notices, orders and other processes
of this Honorable Court.
MATERIAL FACTS
3. Defendant Macopa Gomez is the registered owner of a
parcel of land located st Munitinlupa City (Leased Premises) as
evidenced by Transfer certificate of Title No. 11111.1
1

A copy of the Transfer certificate of Title No. 11111 is attached hereto and made an
integral part hereof as ANNEX A

4. On January 7, 2001, plaintiff entered into a Contrract of


Lease2 with defendant Macopa Gomez for the use and lease the
Premises for a period of fifteen (15) years from said date.
5. On January 2, 2006, defendant Juris Doctoris Manalo wrote
a letter to plaintiffs president asking that from said date, all rents for
the leased premises should be paid to him as the owner of the land.
Furthermore, defendant Manalo avers that said leased premises were
sold to him by defendant Macopa Gomez 3 and as a result,Transfer
Certificate of Title No. 222224 was issued in his favor.
6. Subsequently, plaintiffs president inquired to defendant
Gomez about defandant Manalos letter. Defendant Gomez, however,
denies that there was a change in ownership claiming that the deed
of sale between her and defendant Manalo was fictitious. Moreover,
defendant Gomez asks that all rents on the leased premises still be
paid to her as the true owner of the land.
7. Confronted with the conflicting claims of ownership, plaintiff
held in abeyance payment of rentals for the leased premises and
demanded of defendants Macopa Gomez and Juris Doctoris Manalo
to interplead and litigate their respective claims.
FIRST CAUSE OF ACTION
The foregoing paragraphs are repleaded and incorporated
herein by reference
SECOND CAUSE OF ACTION
The foregoing paragraphs are repleaded by reference.
PRAYER
WHEREFORE, it is respectfully prayed before this Honorable
Court to issue an order directing defendants to interplead with one
another so as to determine their respective rights and claims and to
allow plaintiff to recover his expenses and the costs of this suit as first
lien upon the subject of this action.
2

A copy of the Contract of Lease is attached hereto and made an integral part hereof as
ANNEX B
3
A copy of the deed of sale between Macopa Gomez nd Juris Docturis Manalo is
attached hereto and made an integra part hereof as ANNEX C
4
A copy of the Transfer certificate of Title No. 22222 is attached hereto and made an
integral part hereof as ANNEX D

[name of law firm]


Counsel for Plaintiff
th
8 Floor, Haliwell Center,
1329 Prescott Street,
Muntinlupa City
T +63 2 818 6756-59
F +63 2 815 7396; 568 1234
inquiry@lawoffice.com
By:
[name of lawyer]
8 Floor, Haliwell Center,
1329 Prescott Street,
Muntinlupa City
PTR No. 8765498/01.01.14/Muntinlupa
Roll No. 76549
IBP Lifetime No.48387
T +63 2 818 6756-59
F +63 2 815 7396; 568 1234
[lawyersemail] @lawoffice.com
MCLE Certificate No. 12579
th

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