3.

Plaintiff be ordered to pay actual damages amounting to PHP

250,000.00 for the filing fees and lawyers fees incurred; PHP
1,000,000.00 for moral damages on account of the shame
experienced by the defendant; and PHP 1,000,000.00 as
exemplary damages.
Other reliefs as may be just and equitable under the circumstances are
likewise prayed for.
Quezon City for Valenzuela City, 03 February 2017.

TERENCE LUKE B. DOMINGO

Counsel for Defendant
Public Attorney IV
Public Attorneys Office
National Irrigation Authority Road
Quezon City
Roll of Attorney No.: 109292
IBP Lifetime Member ID No.: 384717
PTR Receipt No.: 572921 (Quezon City, 19 January 2017)
MCLE Exemption No.: 8281900

SUBSCRIBED and SWORN to before me this ____________________ in

___________________________ by Affiant who presented to me his Postal
ID No. PRN D 9416-0470-481 P (2034-3386), which is issued by the
Philippine Postal Corporation, Main Office at Lawton St., Manila and valid
until 21 September 2019.

Copy furnished:

Atty. Donna Ingusan

Counsel for Plaintiff
1900 Pureza St.
Sampaloc, Manila
EXPLANATION
A copy of this pleading was served upon counsel for plaintiff via
registered mail due to lack of material time and lack of adequate personnel
to have this served personally.
REPUBLIC OF THE PHILIPPINES }
CITY OF QUEZON } S.S.
X---------------------------------X

VERIFICATION and CERTIFICATION OF

NON-FORUM SHOPPING
I, TERENCE LUKE B. DOMINGO, single, Filipino, of legal age,
and a resident of Unit 214, St. John Condominium, 139 Scout Rallos
Extension, Brgy. Sacred Heart, Quezon City, NCR, after having been duly
sworn in accordance with law, do hereby state:
1. That I am the plaintiff in the above-entitled case and have caused this
Complaint for Forcible Entry to be prepared by my duly appointed
counsel;
2. That I read and understood its contents which are true and correct of
my own personal knowledge and/or based on authentic records;
3. That I have not commenced any action of proceeding involving the
same issue in the Supreme Court, the Court of Appeals or any other
tribunal or agency;
4. That to the best of my knowledge, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals or any tribunal or
agency, and
5. That, if I should learn thereafter that a similar action or proceeding
has been filed or is pending before these courts of tribunal or agency, I
hereby undertake to report that the fact to the Court within five (5)
days therefrom.
IN WITNESS WHEREOF, I have hereunto set my hand on this ____
day of __________________,20____.

TERENCE LUKE B. DOMINGO

Affiant
SUBSCRIBED and SWORN to before me a Notary Public for and in
___________________________ by Affiant who presented to me his Postal
ID No. PRN D 9416-0470-481 P (2034-3386), which is issued by the
Philippine Postal Corporation, Main Office at Lawton St., Manila and valid
until 21 September 2019.