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REPUBLIC OF THE PHILIPPINES

FIFTH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES

LIGAO CITY, BRANCH

AVELINA R. CORTES,

Plaintiff,

Versus Civil Case No.______

For Forcible Entry

Spouses OLYMPIO ALMAZAR, and

CLEMENTINA O. ALMAZARDefendants,

x-----------------------------------------------------x

COMPLAINT

PLAINTIFF, through counsel and to this Honorable Court,

respectfully avers that:

1) Plaintiff is of legal age, married, Filipino and a resident of

No. 3 Augustus Street, B. F. Resort Village, Las Pinas City.

2) Defendant spouses are of legal age, Filipinos with residence

at Sta. Cruz, Ligao City, where they may be served with summons and

other court processes;

3) Plaintiff is the absolute and registered owner of a 450-square

meter lot situated at a residential area in Sta. Cruz, Ligao City, and

which she purchased from Antonio Corpus on September 9, 2003;4) Plaintiff has in her possession the original owners duplicate

of TCT No. T-18910 and a certified copy of Tax Declaration No.

2013-02-008-04-064;

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5) Sometime in August of 2012, defendants, taking advantage

of plaintiffs prolonged absence brought about by her change of

residence to her current residence, surreptitiously entered plaintiffs

vacant lot and started occupying the same;

6) On January 14, 2013, plaintiff discovered that not only did

defendants intruded into her lot but they had constructed a house

thereon without her authorization nor consent ;

7) Despite sending a demand letter dated on January 21, 2013,

asking the defendants to vacate the lot within ten (10) days from

notice, defendants continued to occupy the subject property;

8) On February 7, 2013, plaintiff filed a complaint against

defendants with the Office of the Barangay Chairman of Sta. Cruz,

Ligao City;

9) During the conferences, defendants refuse to vacate the lot

contending that they bought the same from a certain Leonila Sevino

sometime in August 2012.

PRAYER

WHEREFORE, it is respectfully prayed that after due hearing,

judgment be rendered in favour of the plaintiff:

1) For the restitution of the abovementioned premises and

removal of the improvements thereon and

2) For the payment of damages, attorneys fees and costs ofsuit.

Other reliefs just and equitable under the premises are likewise

prayed for.

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Ligao City, April 29, 2013

NOEL ALLEN R. BOSE

Counsel for Plaintiff24 Mangga St., Dona Paz Subd.,

Phase 1, Cruzada, Legaspi City

PTR No. 613452552/5-20-10/L.C.

Roll of Attorneys No. 39899IBP No. 621123/7-16-09/Makati

CERTIFICATION AND VERIFICATION

I, Avelina R. Cortes, of legal age, Filipino and a resident of No.

3 Augustus Street, B. F. Resort Village, Las Pinas City, avers under

oath that:

1) I am the plaintiff in the above entitled case; I caused the

preparation of the foregoing complaint; and all material allegations

therein are true of my own knowledge;

2) I have not commenced 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) daysfrom such knowledge to this Honorable Court.

AVELINO R. CORTES

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SUBSCRIBED AND SWORN to before me this ____ day ofJuly, 2013 affiant exhibiting to me his CTR No. ____________,

issued on _______________, at _________________.

Doc. No. ______

Page No. ______Book No. ______

Series of 2013