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DONALD CASTILLO,
Plaintiff, CIVIL CASE NO. ___________
- versus - - for -
COMPLAINT
PLAINTIFF by counsel, to this Honorable Court, most respectfully avers that:
2. Defendant Atty. Cesar Ramirez is also of legal age, married, Filipino and a
resident of Naguilian, Isabela, where he may be served with summons and
other processes of this Honorable Court;
3. The plaintiff is the owner of a parcel of land located in San Mateo, Isabela,
containing an area of ONE MILLION(1,000,000.00) SQUARE METERS, more
or less, which realty is titled in his name as evidenced by Transfer
Certificate of Title (TCT) No. T-222222222 of the Registry of Deeds for the
Province of Isabela, photocopy of which is hereto attached as Annex “A”
and made an integral part of this complaint;
5. On January 28, 2011, defendant together with hired laborers without the
knowledge, consent and authority of the plaintiff, by force, strategy and
stealth entered the land described in paragraph 3 hereof, encroached on
and took possession of a portion of the said land having an area of 500,000
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11. The instant action is brought within the period of one year, reckoned from
the date of actual possession of the subject land by the defendant on
January 28, 2011.
PRAYER
2. Ordering the defendant to remove any structure which he, in bad faith,
have erected in the area occupied by him or, in default thereof, to order
the demolition of his building or structures which are standing in the land,
all at the expense of the defendant.
3. I have read and understood the contents of this complaint and all
the allegations contained therein are true and correct of my own personal
knowledge and based on authentic documents.
4. I hereby certify that I have not commenced any other action or
proceedings involving the same issues in the above entitled case before the
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Donald Castillo
Plaintiff
Doc. No _____;
Page No. ____;
Book No.____;
Series of 2012.
Ejectment Case: Forcible Entry or Unlawful
Detainer Explained
Page 2
Page 3
"x x x.
“x x x x
x x x."
Preliminary Injunction
Category: Civil Procedure
References:
2Id.
3Id.
RULE 70
FORCIBLE ENTRY AND UNLAWFUL DETAINER
Sec. 6. Answer.
Within ten (10) days from service of summons, the
defendant shall file his answer to the complaint and serve
a copy thereof on the plaintiff. Affirmative and negative
defenses not pleaded therein shall be deemed waived,
except lack of jurisdiction over the subject matter. Cross-
claims and compulsory counterclaims not asserted in the
answer shall be considered barred. The answer to
counterclaims or cross-claims shall be served and filed
within ten (10) days from service of the answer in which
they are pleaded.
Upon motion of the plaintiff, within ten (10) days from the
perfection of the appeal to the Regional Trial Court, the
latter may issue a writ of preliminary mandatory injunction
to restore the plaintiff in possession if the court is satisfied
that the defendant’s appeal is frivolous or dilatory, or that
the appeal of the plaintiff is prima facie meritorious.