REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11th JUDICIAL REGION
BRANCH XVI

Naruto Uzumaki,
Plaintiff,

- versus - Civil Case No. 45628

For: Receivership
Neji Hyuga,
Defendant.
x---------------------------------------x

COMPLAINT

Complainant by the undersigned attorney, and unto this Honorable

Court, respectfully avers that:

1. Plaintiff, Naruto Uzumaki, of legal age, Filipino citizen, single with

residence and postal address at 123 Kalamares St. Brgy. NHA
Buhangin Davao City;
2. Defendant, Neji Hyuga is of legal age, Filipino citizen, single and
residence and postal address at Km. 6,Dona Salud, Sasa, Davao City;
3. Plaintiff is the owner as the pro-indiviso owner with the defendant a
property in litigation located in Brgy. Tibungco, Davao City,
Philippines, which has the fair market value of FIVE HUNDRED
THOUSAND PESOS (500,000.00);
4. The defendant is in actual possession of the property in litigation and
as such, he is in control of the produce of the property pending
litigation;
5. The produce and income from said property are in danger of being
lost, removed or materially injured unless a receiver be appointed to
guard and preserve the same;
6. The defendant is hopelessly insolvent for he is heavily indebted to
various persons;
7. The appointment of a receiver in this case is the most convenient and
feasible means of preserving, administering or disposing of the
property in litigation.

Davao City, February 12, 2020.

 ADRIAN PAJARO
Counsel for Plaintiff
Until December 31, 2021
Attorney’s Roll No. 10772
PTR No. 7862245 B; 01-02-20; Davao City
IBP O.R. No. 024454; 01-02-20; Davao
City

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF DAVAO DEL SUR) S.S
IN THE CITY OF DAVAO………..)
X…………………………………….X

VERIFICATION AND CERTIFICATION

I, Naruto Uzumaki, of legal age, after having been duly sworn in

accordance with law, depose and state that:
1. I am a petitioner in the above-stated case representing the republic
of the Philippines;
2. I caused the preparation of the foregoing petition;
3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and/or on the basis true and
authentic records.
4. I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;
 6. If I should thereafter learn that a similar action or proceeding has
been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signatures this 2 nd

day of February 2019, at Davao City, Philippines.

                            
Naruto Uzumaki
Affiant

SUBSCRIBED AND SWORN to before me in the City of Davao this

th
30 day of April 2016, by Naruto Uzumaki , who has satisfactorily proven
her identity to me through his Voter’s ID issued by the PRC bearing his
photograph and signature and with VIN 1123-12323232-4, that he is the
same person who personally signed the foregoing document before me and
acknowledged that he executed the same.

WITNESS MY HAND AND SEAL this 2nd day of February 2020

in Davao City, Philippines.
 NOTARY PUBLIC
Doc. No. 61;
Page No. 13;
Book No. 01;
Series of 2020.