REPUBLIC OF THE PHILIPPINES

First Judicial Region

Municipal Trial Court
Branch 5
Baguio City

JESSICA CAMILLE P. EDQUILAG,

Plaintiff,
-versus- Civil Case No. 18-042756
BRIAN V. SEGISMUNDO and, For: Forcible entry
BEA ROSE V. SEGISMUNDO,
Defendants.
x-----------------------------------x

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and

unto this Honorable Court, most respectfully avers that:

1. The plaintiff is of age and a resident of 4 Baguio-Bua-Itogon

Road cor. Outlook Drive South, Baguio City, Philippines;
2. Defendants are of age, Filipinos, with residence at 128
Tangerine St., Zenaida II Subdivision, Concepcion Uno, Marikina City,
where they may be served with summons and other court processes;
3. The plaintiff is the absolute owner of a fenced strawberry
farm located in 4 Baguio-Bua-Itogon Road cor. Outlook Drive South,
Baguio City;
4. Sometime in June 27, 2018, defendants, forcefully destroyed
the fence surrounding the said property, and cleared the property from
the seventy (70) strawberry shrubs planted therein to build their
shanties without any authorization nor consent from the plaintiff;
5. Despite repeated demands to vacate the premises, defendants
continued to occupy the subject property, thereby depriving the plaintiff
of lawful possession thereof; and
6. As a result of the defendants’ unlawful occupation of the
property, plaintiff suffered actual damages of ONE HUNDRED SIXTY
THOUSAND PESOS (Php 160,000.00), representing the value of the
fence and the strawberry shrubs. Receipts for the construction of the
fence, as well as the expenses incurred in maintaining and rehabilitating
the strawberry shrubs are here attached as Annexes “A”, “B-1”, and “B-
2”.

WHEREFORE, premises considered, it is respectfully prayed unto

this Honorable Court that, after due hearing, judgment be rendered in
favor of the plaintiff.

a. For the restitution of the abovementioned premises; and

b. For the payment of damages, attorney’s fees and costs of suit.

Other reliefs just and equitable are likewise prayed for.

City of Baguio, Philippines, July 16, 2018

LENNON MCCARTNEY AND ASSOCIATES LAW OFFICE

Counsel for the Plaintiff
214 Penny Lane St., Brgy. Malinta, Valenzuela City

By:

JOHN LENNON
Roll of Attorneys No. 107136
IBP No. 795004/20 April 2018/Pasig City
PTR No. 2950426/24 April 2018/Manila
MCLE Compliance No. V-0014727/25 June 2018

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

REPUBLIC OF THE PHILIPPINES)

CITY OF PASIG ) S.S.
 I, JESSICA CAMILLE P. EDQUILAG, Filipino, of legal age,
residing at 4 Baguio-Bua-Itogon Road cor. Outlook Drive South, Baguio
City, after being sworn to in accordance with law, deposes and says that:

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

2. The facts stated in the above complaint are true and correct
to the best of my knowledge and authentic records;
3. I have not commenced any action or filed any claim involving
the same issues in any court, tribunal or quasi-judicial agency and, to the
best of my knowledge, no such other action or claim is pending in them;
and
4. If I should learn that the same or similar action or claim has
been filed or is pending after its filing, I shall report that fact within five
(5) days from notice to the court or where the complaint or initiatory
pleading has been filed.

July 16, 2018, Pasig City, Philippines.

JESSICA CAMILLE P. EDQUILAG

Affiant

SUBSCRIBED AND SWORN TO before me this 17th day of July

2018 in Pasig City, Philippines, affiant exhibiting to me his competent
evidence of identity by way of Passport with number XX0971748, issued
at Manila, Philippines on May 24, 2017.

NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2018.