February 6, 2019 Legal Technique

and Logic
Mid-Term Examination

Submitted by: Lorevera Krishna Abellar

Submitted to: Mohammad Mon-em Abangad
 REPUBLIC OF THE PHILIPPINES

METROPOLITAN CIRCUIT TRIAL COURT

Datu Odin Sinsuat, Maguindanao
2nd Municipal Circuit Trial Court

Kris C. Aquino,
Plaintiff,
CIVIL CASE No. xxxx
-versus- FOR: Unlawful Detainer

Spouses Gretchen A. Barretto and Tony Boy C. Barretto

Defendant.

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

COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto
this Honourable Court, most respectfully avers:
1. That the plaintiff, KRIS C. AQUINO, is a legal age, Filipino citizen,
widow, with residence at Lugay-Lugay, Cotabato City;
2. That the defendant, spouses GRETCHEN A. BARRETTO and TONY
BOY C. BARRETTO, of legal age, Filipino citizen, with residence at
Crossing Simuay, Sultan Kudarat, Maguindanao, where they may be
served with summons and other court processes;
3. The plaintiff is the rightful possessor of the disputed land located at
Crossing Simuay, Sultan Kudarat, Maguindanao, she being the widow
of its registered owner PHILIP S. AQUINO;
4. Since 1980, defendants started occupying the land and the deceased
owner, husband of the plaintiff, did not opposed and just tolerated the
possession of the land;
5. On December 17, 2018, the plaintiff sent a letter of demand to vacate
and consequently restore the possession of the land because she would
already be using the same for own use;
6. Despite said letter of demand which was repeated by oral demands, the
defendant failed to vacate and restore the possession of the land to the
plaintiff;
 7. By reason of failure of the defendant to vacate the land, the plaintiff
was compelled to file this complaint engaging the services of counsel
in the amount of P100,000.00.
WHEREFORE, premises considered, it is most respectfully prayed
unto this Honourable Court that, after hearing, judgment be rendered ordering
the defendant:

1. To vacate and restore the possession of the land;

2. To pay the amount of P10,000.00 per month as a compensation for the
reasonable use of the land until they finally vacate the said land;
3. To pay the plaintiff the cost of the suit P100,000.00.
Datu Odin Sinsuat, Maguindanao, January 30, 2019

LOREVERA KRISHNA M. ABELLAR

Counsel for Plaintiff
Datu Odin Sinsuat, Maguindanao
Roll of Attorney No. 0911
IBP Lifetime Member No. 0722/07-07-07/Manila
PTR No. 1219/05-19-07/Manila
Republic of the Philippines )
Datu Odin Sinsuat, Maguindanao ……)) S.S.
x---------------------------------------------x

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

I, KRIS C. AQUINO, of legal age, Filipino citizen, widowed, and a resident

of Crossing Simuay, Sultan Kudarat, Maguindanao, after having been duly
sworn to in accordance with law do hereby depose and say:

1. That I am the plaintiff in the above-entitled case;

2. That I have caused the preparation of the foregoing complaint and
have read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records.

KRIS A. AQUINO
Plaintiff

SUBSRCIBED and SWORN to before me this ____ day of _________, 2019

at Datu Odin Sinsuat, Maguindanao.

LOREVERA KRISHNA M. ABELLAR

Notary Public
Until Dec. 31, 2019
PTR No. 1219/05-19-07/Manila
Issued at Datu Odin Sinsuat, Maguindanao