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JOHN DOES,
JANE DOES
Respondents.
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COMPLAINT
THE PARTIES
FACTS
6. Complainant is the registered owner of a parcel of land with an area
of NINE HUNDRED EIGHT (908) SQUARE METERS covered under
Title No. __________ located at __________; Machine copy of TCT No.
______is hereto attached as Annex “B”;
9. From the time of the sale between herein complainant and the PNB,
complainant was unable to take possession and enjoy said property;
WW Corp. filed for the declaration of nullity of the sale made to PNB
(together with another property sold to a different person) but the
same was ordered as valid by virtue of the Order of the Regional
Trial Court, Branch ___ dated __________; Machine copy of the Order is
hereto attached as Annex “D”;
CAUSE OF ACTION
11. It has been more than a decade since complainant departed with
her hard-earned money for its acquisition yet complainant was
unable to enjoy said property since occupants therein refused to
vacate;
13. Several demands were made for them to peacefully vacate the
property however, the efforts of herein complainant were proven
futile;
14. A final demand letter was sent to them wherein demand to vacate
was made with further demand of rental of Php5,000.00/month
should they fail and refuse to heed said demand; the same was
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received on ________; machine copy of the received letter is hereto
attached as Annex “E”;
16. Defendants are the ones enjoying the property while complainant is
the one burdened with paying the taxes due from said property from
the time she bought the property from the PNB up to present;
receipts of the property taxes are hereto attached as Annexes
“______”;
17. With this, complainant was unable and is unable to reap fruits of her
investments hence, she is entitled to damages;
20. Complainant is willing and able to post bond in the amount that may
be required by this Honorable Court;
PRAYER
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D. Ordering defendants to pay complainant the amount of
Php500,000.00 as damages
By
Copy furnished:
John Does
Jane Does