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Republic of the Philippines

6TH JUDICIAL REGION


Regional Trial Court
Branch 25
Iloilo City

DAVID A. SILVA
Plaintiff,

-versus- CIVIL CASE No. 12-2019-12


For: EJECTMENT (FORCIBLE ENTRY)

MARCO B. LUIS
Defendant.
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COMPLAINT

PLAINTIFF, through the undersigned counsel, and unto this


Honorable Court most respectfully submits this Complaint for Forcible
Entry and in support hereof makes the following assertions:

1. Plaintiff DAVID A. SILVA, is residing at #4 Poblacion 4, Oton,


Iloilo City, where he may be served with court order and other
processes;

2. Defendant MARCO B. LUIS is a resident of #3 Poblacion 2,


Oton, Iloilo City where he may be served with summons, order
and other court processes;

3. Plaintiff became owner of a certain parcel of land, through a Deed


of Sale from the original owner, JUAN C. ASIONG (A copy of
the Deed of Sale is hereto attached as Annex “A”);

4. The parcel of land, situated in #1 Poblacion 1, Oton, Iloilo City is


covered by Transfer of Certificate of Title No. 1234-7890 issued
by the Register of Deeds at Iloilo City and is more particularly
described, as follows:

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“A parcel of residential land situated at #1 Poblacion 1,
oton, Iloilo City designated as Lot No. 10626-E-3 part
containing an area of One Hundred Fifty (150) square meters
bounded on the North by road right of way: on the East by Lot
No. 10626-E-4: on the South by Lot No. 10626-D: and on the
West by Lot No. 10626-E, part covered by ARP No. 2015-12-
0011-00753 declared in the name of David B. Silva. with an
assessed value of P 2000, 000.00”

(Copy of TCT- 1234-7890 is hereto attached as ANNEX “B”);

5. Herein Defendant, through stealth and strategy, occupied the


parcel of land in question and refuses to vacate the same despite
repeated oral and written demands. (Copy of the written
demand is hereto attached as Annex “C”);

6. The same acts of the Defendant compelled the Plaintiff to incur


damages consisting of attorney’s fees in the amount of Thirty
thousand pesos (P30,000.00) pesos and filing fee, cost of
transportation and other miscellaneous accommodation of its
lawyers and other personal expenses to be incurred in attending
the hearings of this case in the amount of FIFTY THOUSAND
PESOS (Php 25,000.00).

7. This action is governed by the Rules on Summary Procedure;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed


of this Honorable Court that, after the proceedings, judgment be
rendered in favor of the Plaintiff and ordering the Defendant and all
persons claiming rights under him to:

(a) Permanently VACATE the premises in question and give the


immediate right of possession to the Plaintiff;

(b) Pay plaintiff the amount of Thirty Thousand Pesos (P30,000.00)


by way of attorney’s fees and Twenty-Five Thousand Pesos
(P25,000.00), by way of other litigation expenses; and,

(c) Pay the cost of this suit.

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Plaintiff prays for such other remedies and reliefs as may be deemed
just and equitable under the premises.

January 16, 2019 Oton, Iloilo City.

ATTY. ISIDORE T. TAROL III


Notary Public
Valid until December 31, 2023
Roll of Attorneys No. 753000
PTR NO. 12345-753, Iloilo City, June 27, 2023
IBP NO. 753-12345, Iloilo City, June 27, 2023
MCLE Compliance. No. IV-12345-7530

REPUBLIC OF THE PHILIPPINES)


PROVINCE OF ILOILO ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION


AGAINST NON- FORUM SHOPPING

I, DAVID A. SILVA, of legal age, after being duly sworn to in


accordance with law, depose and attest:

That I am the petitioner in the above-titled case; that I have


caused the preparation of the foregoing petition and understood the
contents thereof, and I hereby declare that all the allegations contained
therein are true and correct according to my knowledge and belief.

Furthermore, I hereby certify that I have not filed nor caused to


be filed any other similar case involving the same issues in the Supreme
Court, Court of Appeals or any other tribunal or agency and that,
should there be any other such case/s that may have been filed, I
hereby bind myself to inform the Court of such fact within five (5) days
from the discovery thereof.

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IN WITNESS WHEREOF, I have hereunto set our hand this
16th day of January 2019, Oton, Iloilo City.

DAVID A. SILVA
Affiant
TIN No. 1234-7899

SUBSCRIBED AND SWORN to before me, in the City of


Quezon, this 16th day of January 2019, Oton, Iloilo City, Philippines,
affiant having exhibited to me his TIN No. 1234-7890 issued at Iloilo
City, Philippines.

ATTY. ISIDORE T. TAROL III


Notary Public
Valid until December 31, 2023
Roll of Attorneys No. 753000
PTR NO. 12345-753, Iloilo City, June 27, 2023
IBP NO. 753-12345, Iloilo City, June 27, 2023
MCLE Compliance. No. IV-12345-7530
Doc. No. 10;
Page No. 3;
Book No.1;
Series of 2023

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