THIRD PARTY COMPLAINT

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF BUKIDNON
JUDICIAL DISTRICT
BRANCH X

ANGEL LOCSIN,
Plaintiff,

-versus- CIVIL Case No. 20190009

JANE DE LEON,
Defendant.
x-------------------------------------x

JANE DE LEON,
Third-Party Plaintiff

-versus-

PIOLO PASCUAL,
Third-Party Defendant.

THIRD-PARTY COMPLAINT

THIRD-PARTY PLAINTIFF, through counsel and with leave of this

HONORABLE COURT to file this Third-Party Complaint, respectfully states:
1. Angel Locsin, Plaintiff filed a complaint against Jane De Leon,
Defendant and Third-Party Plaintiff.
2. Angel Locsin alleges that the SALE of a parcel of land covered
by TCT No. T-14344 with Jane De Leon caused damage to him.
3. Jane De Leon, in GOOD FAITH, bought the parcel of land
covered by TCT No. T-14344 from Piolo Pascual.
4. Jane De Lon, in GOOD FAITH considering that the SALE
between Jane De Leon and Piolo Pascual is free from any
impediment, sold the parcel of land covered by TCT No.
T-14344 to Angel Locsin.
5. The parcel of land covered by TCT No. T-14344 was foreclosed
by the Land Bank of the Philippines for the reason that it
was mortgaged by Inigo Pascual, co- owner of the parcel of
land covered by TCT No. T-14344.
6. If Angel Locsin recovers against Jane De Leon any judgment for
their damages then Jane De Leon is entitled to judgment
against Piolo Pascual for all such sums since the SALE of the
parcel of land covered by TCT No. T-14344 was the sole
cause of Angel Locsin’s damages and injuries.

WHEREFORE, it is respectfully prayed that Jane De Leon, Defendant

and Third Party Plaintiff, can demand judgment against Piolo Pascual, Third
Party Defendant, for all sums that may be adjudged against Jane De Leon,
as Defendant, in favor of Angel Locsin, as Plaintiff, together with all costs
incidental to the defense of the principal suit.

Casisang, Malaybalay City; 12 December 2019.

Counsel for Plaintiff

Casisang, Malaybalay City
Republic of the Philippines )
City of Malaybalay ) S.S

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, Jane De Leon, of legal age, Filipino, single, and a resident of Integrated Village,
Poblacion, Pangantucan,Bukidnon, on oath, state:

1. That I as the Third-Party Plaintiff in the above-entitled case have caused this Third-
Party Complaint to be prepared; that I read and understood its contents which are
true and correct of my own personal knowledge and/or based on true records;

2. That I have not commenced any action or proceeding involving the same issue and
specifically the same check/s in the Supreme Court, the Court of Appeals or any other
tribunal or agency, particularly before the Office of the Provincial Prosecutor of
Bukidnon; that to the best of my knowledge, no such action or proceeding is pending
in the Supreme Court, the Court of Appeals or any other tribunal or agency, and that,
if I should learn thereafter that a similar action or proceeding has been filed or is
pending before these courts or tribunal or agency, I undertake to report that fact to
the Court within five (5) days therefrom.

IN WITNESS WHEREFOR, the aforementioned parties have hereunto

set their hands this 25 th day of November 2019 at the City of Malaybalay,
Province of Bukidnon, Philippines.

JANE DE LEON

Third-Party Plaintiff
Passport No. 000003
Issued on 1st of February 2017
Issued at Cagayan de Oro City 

SUBSCRIBED AND SWORN to before me this 12th day of

December 2019 at Malaybalay City, Philippines.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2019.