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PEDRO SY,
Plaintiff
COMPLAINT
Plaintiff by counsel, to this Honorable Court, respectfully avers that:
1. Plaintiff PEDRO SY, of legal age, Filipino and resident of No. 2
Building, Calumpit, Bulacan;
2. Defendant JUAN DELA CRUZ, of legal age, Filipino and a resident
of No. 1 Building, Calumpit, Bulacan, where he may be served with
summons and other processes;
3. The plaintiff is the owner of parcel of land located in No.3 Land,
Calumpit, Bulacan, containing an area of 250sqm, more or less which
realty is titled in the name as evidence by Transfer Certificate of Title
No. T22222 of Registry of Deeds Bulacan, photocopy of TCT No.
T22222 is here to attach and made an integral part of Annex A;
4. Plaintiff has been in peaceful possession of the land continuously and
uninterrupted for more than ten (10) years;
5. On January 28,2015, defendant together with hired laborers without
knowledge, consent and authority of the plaintiff, by force, strategy
and stealth entered that land described in paragraph 3, encroached on
and took possession of a portion of the land having an area of 200sqm
with the following boundaries: on the Northeast by the remaining
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Pedro Sy
Plaintiff