REPUBLIC OF THE PHILIPPINES

5
TH
JUDICIAL REGION
MUNICIPAL TRIAL COURT IN CITIES
LIGAO CITY

CARIDAD A. REYES, represented by
Her attorney-in-fact, Jadelyn E. Pulido,
Plaintiff,


- versus - Civil Case No. __________
For Forcible Entry

SPS. CELESTINO P. PINTOR and
GUADALUPE S. PINTOR and all
Persons claiming rights under them,
Defendants,
x--------------------------------------------x


C O M P L A I N T

PLAINTIFF, through counsel and to this Honorable Court,
respectfully avers that:

1. Plaintiff is of legal age, widow, Filipino and a resident of
No. 3 Augustus Street, B.F. Resort Village, Las Pias City.

2. Plaintiffs attorney-in-fact, Jadelyn E. Pulido, is of legal
age, single, Filipino and a resident of Asiawealth Towers, Leveriza
Street, Pasay City.

3. Defendants Celestino P. Pintor and Guadalupe S. Pintor
are husband and wife, both of legal age, Filipinos and residents of Sta.
Cruz, Ligao City where they may be served with summons and other
court processes;

4. Plaintiff is the absolute and registered owner of a vacant
450-square meter lot situated at a residential area in Sta. Cruz, Ligao


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City in the province of Albay. The lot is covered by Transfer
Certificate of Tile No. T-18910 after such was purchased by the
plaintiff from a certain Ramon S. Go on September 9, 2005.

5. The subject property is described as follows:

A parcel of land (Lot No. 4344 of the
Cadastral Survey of Ligao), with the improvements
thereon, situated in the Barrio of Sta. Cruz,
Municipality of Ligao. Bounded on the N. by Lot
No. 1433; on the E. by Lot No. 4343; on the SE. by
a road; and on the W. by Lot No. 4345. Beginning
at a point marked 1 on plan, being S. 35 deg. Oy
E., 526.06 m. from B.B.M. No. 26; thence S. 74
deg. 50 W., 24.85 m. to the point 2; thence N. 4
deg. 18 W. 20.93 m. to the point 3; thence N. 88
deg. 54 E., to the point of beginning; containing an
area of four hundred and fifty (450) square meters
more or less. All point referred to are indicated on
the plan; bearings 19xx- November 19xx.


6. Under Tax Declaration of Real Property No. 207-02-008-
04-064 issued by the Ligao City Assessors Office on December 15,
2012. The Subject property has an assessed value of P37,500.00;
Attached and made integral part hereof are the photocopies of TCT
No. T-18910 and Tax Declaration of Real Property No. 207-02-008-
04-064 as Annexes A and B, respectively.

7. Sometime in 2006, taking advantage of the plaintiffs
prolonged absence brought about by the transfer of her residence from
Sta. Cruz, Ligao City to No. 3 Augustus Street, B.F. Resort Village,
Las Pias, City, the defendant spouses surreptitiously entered the
plaintiffs vacant lot and started occupying the same without the
consent and knowledge of the plaintiff.




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8. On May 10, 2013, when the plaintiff visited the subject
property, she discovered that the defendants had not only intruded into
her lot but constructed a house as well.

9. The plaintiff made numerous demands, though verbally,
for the defendants to vacate the premises but such was ignored by the
latter. On October 5, 2013, the plaintiff through her counsel furnished
the defendants with a demand letter, requiring the latter to vacate the
plaintiffs lot within ten (10) days from notice. The defendants
received the demand letter on October 11, 2013 as evidenced by the
Registry Return Receipt but such was ignored and the spouses have
not vacated the premises until now; Attached and made integral part
hereof are the photocopies of the Demand letter dated October 5,
2013, the Registry Return Receipt dated October 11, 2013 and the
dorsal portion as Annexes C, D and D-1, respectively.

10. On November 5, 2013, the plaintiff filed a complaint
against the defendants with the office of the Barangay Chairman of
Sta. Cruz, Ligao City. The Barangay Chairman issued to the plaintiff
on December 15, 2013 a Certificate to File Action for failure of the
partied to reach a settlement; Attached and made integral part hereof
is the Certificate to File Action as Annex E.

11. Due to defendants unwarranted refusal to comply with
the plaintiffs patently valid demand, plaintiff was constrained to
institute the instant action and retain the services of counsel thereby
incurring litigation expenses and expenses for attorneys fees for
which the defendants should be ordered to pay the plaintiff the sum of
P100,000.00.







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P R A Y E R

WHEREFORE, it is respectfully prayed that, after hearing,
judgment be rendered ordering the defendants:

1. To vacate and turn over to the plaintiff full control
and possession of the subject land.

2. To pay the plaintiff the sum of P100,000.00 by
way of litigation expenses and attorneys fees.

3. To pay the cost of suit.
Other reliefs, just and equitable under the premises are likewise
prayed for.

Pasay City, January 21, 2010


JADELYN E. PULIDO
Counsel for Plaintiff
Asiawealth Tower, Leveriza St., Pasay City
PTR No. -------/x-xx-xx/X.X.
Roll of Attorneys No. -----
IBP No. ------/x-xx-x/Pasay City




















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CERTIFICATION AND VERIFICATION

I, CARIDAD A. REYES, of legal age, Filipino and resident at
the above given address, avers under oath that:

1. I am the plaintiff in the above entitled cause; I caused the
preparation of the foregoing complaint; and all material allegations
therein are true of my own knowledge.

2. I have not commence any action or filed any claim
involving the same issues in any court, tribunal or quasi-judicial
agency and to the best of my knowledge, no such other action or claim
is pending therein;

3. Should I hereafter learn that the same or similar action or
claim has been filed or is pending before any court, tribunal or quasi-
judicial agency, I undertake to report said fact within five (5) days
from such knowledge to this Honorable Court.



CARIDAD A. REYES


SUBSCRIBED AND SWORN to before me this 26th day of
January, 2014, affiant exhibiting her CTR No. _____________, issued
on ________, at ____________________________.










Doc. No. _______
Page No. _______
Book No._______
Series of 2014