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TONYO PRITO,
Plaintiff,
Civil Case No.:________
For:
- Versus -
Declaration of Nullity of
Real Estate Mortgage
Gardo VALENCIANA,
Defendant.
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COMPLAINT
COMES NOW, Plaintiff, by the Public Attorney’s Office, to the
Honorable Court, most respectfully states:
THE PARTIES
9. Plaintiff explained to the defendant that she and her husband did
not execute the Real Estate Mortgage considering that it was the first time
plaintiff met the defendant and it is impossible that her husband could have
executed and signed the said Real Estate Mortgage contract on March 15,
2010 because Prito, Sr. was already dead at that time. As proof, plaintiff
even showed defendant a photocopy of the Certificate of Death of her
husband but defendant still refused to give her the original of TCT No. T-
17625. A copy of the Certificate of Death of Prito, Sr., who died on April 17,
2008, issued by the National Statistics Office is hereto attached as Annex
“C” and forms an integral part of this complaint;