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JEY T. PONCE,
Plaintiff,
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C O M P L A I N T
Plaintiff, by and through the undersigned Counsel unto the Honorable Court, states:
1. Plaintiff is of legal age, Filipino, married, and a resident of #18 Valenzuela St.,
Salud Mitra, Baguio City;
8. The aforesaid act of the Defendant, if not restrained, would work injustice to
the Plaintiff;
11. In order to deter Defendant and other persons from their ilk in performing
similar malicious acts, Defendant should be assessed the amount of P
50,000.00 as and by way of exemplary damages;
12. And finally, in filing this action in order to seek redress for her grievances
and recover damages, plaintiff was compelled to engage the services of the
undersigned Counsel for an agreed fee of P 20,000.00 as and by way of
acceptance fee plus the sum of P1,500.00 as and by way of appearance fee for
each attendance in court during trial.
PRAYER
c. Costs.
d. Other reliefs, just and equitable under the premises, are likewise prayed for.
Respectfully submitted this 1st day of May 2011, in the City of Baguio.
1. I am the plaintiff in the Civil Case Number 4598 for Forcible Entry; I have caused the
preparation of the foregoing complaint; I have read and understood the contents of the
same; and that all the allegations therein are true and correct of my own knowledge and
based on authentic documents;
a. I have not commenced any proceeding involving the same issues before the
Supreme Court, Court of Appeals, or any other Government Agency or Tribunal;
c. If there be any similar action before the Supreme Court, Court of Appeals, or any
other Government Agency or Tribunal, I undertake to report the same within five
(5) days to the court where the original action and certification referred to
herein has been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 1st day of May 2011, in
the City of Baguio, Philippines.
JEY T. PONCE
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 1 st day of May
2011 by Jey T. Ponce, personally known to me, who is the same person who personally
signed before me the foregoing affidavit and acknowledged that she executed the same.
LIYA ORTEGA-RODRIGUEZ
Notary Public
Until December 31, 2012
Doc. No. __78__; PTR No. 050183/Baguio City/01-11-11
Page No. _16__; Roll of Atty. No. 8121983
Book No. I ; IBP Lifetime Membership No. 9031984
Series of 2011. Baguio-Benguet