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REPUBLIC OF THE PHILIPPINES MUNICIPAL TRIAL COURT SURIGAO CITY Branch 02

DENIESE C. CORNYHO Plaintiff, -versusCIVIL CASE No. 01069 For: Ejectment (Forcible Entry)

VHONG N. NIBORROW Defendant. x - - - - - - - - - - - - - - - - - - - - - - - - - - -x COMPLAINT PLAINTIFF, through the undersigned counsel, and unto this Honorable Court most respectfully submits this Complaint for Forcible Entry and in support hereof makes the following assertions: 1. Plaintiff DENIESE C. CORNYHO is residing at No. 124 Purok 4, Cordita Compound, Brgy. San Juan, Surigao City, where he may be served with court order and other processes; 2. Defendant VHONG N. NIBORROW is a resident of No. 80 Purok 3, Tani Compound, Brgy. San Juan, Surigao City where he may be served with summons, order and other court processes; 3. Plaintiff became owner of a certain parcel of land, through a Deed of Sale from the original owner, SIDELICK L. LEE. (A copy of the Deed of Sale is hereto attached as Annex A); 4. The parcel of land situated in No. 81 Purok 3, Tani Compound, Bgy. San Juan, Surigao City, is covered by Transfer of Certificate of Title No. 6010 issued by the Register of Deeds of Surigao City and is more particularly described, as follows: TCT No. T-6010 A PARCEL OF LAND (Lot No. 81 Purok 3, Tani Compound, Bgy. San Juan, Surigao City (LRC) Pcs-5141, being a portion of the consolidation of Lot 80 and 82, Psu-112287 Amd., LRC (GLRO) Rec. No. N-17511), situated in the Tani Compound, Brgy. San Juan, City of Surigao, Surigao del Norte. Bounded on the NE., points 3 to 6, by Lot 79; on the S., points 6 to 1 by Lot 83; on the SW., points 1 to 2, by Lot 85; and on the N., points 2 to 3 by Lot 123, all of the Tani Compound. Beginning at a point marked "1" on plan, being N. 51

deg. 36' E., 1321.76 m. from B.L.L.M. No.1, Brgy. San Juan, Surigao City, Surigao del Norte. (Copy of TCT- 6010 is hereto attached as ANNEX B); 5. That plaintiff had been in the lawful possession of the same land, being owner thereof, since June 16, 2013, until the day and incident in the following paragraph hereof; 6. That, on or about January 21, 2014, herein defendant, through stealth and strategy, occupied the parcel of land in question and refuses to vacate the same despite repeated oral demand; 7. The same acts of the Defendant compelled the Plaintiff to incur damages consisting of attorneys fees in the amount of Thirty thousand pesos (P30, 000.00) pesos and filing fee, cost of transportation and other miscellaneous accommodation of its lawyers and other personal expenses to be incurred in attending the hearings of this case in the amount of FIFTY THOUSAND PESOS (Php 25,000.00). 8. This action is governed by the Rules on Summary Procedure; PRAYER WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court that, after the proceedings, judgment be rendered in favor of the Plaintiff and ordering the Defendant and all persons claiming rights under him to: a) Permanently VACATE the premises in question and give the immediate right of possession to the Plaintiff; b) Pay plaintiff the amount of Thirty Thousand Pesos (P30,000.00) by way of attorneys fees and Twenty Five Thousand Pesos (P25,000.00), by way of other litigation expenses; and, c) Pay the cost of this suit. d) Plaintiff prays for such other remedies and reliefs as may be deemed just and equitable under the premises. February 13, 2014. Surigao City, Surigao del Norte. ATTY. RHIUM TRUCE C. SALVADOR Counsel for Plaintiff Surigao City Roll of Attorneys No. 69010
IBP No. A-1234567, 06/06/06, Surigao City PTR No. A- 1234567, 06/06/06, Surigao City

VERIFICATION/CERTIFICATION OF FORUM SHOPPING Republic of the Philippines) City of Surigao ) S.S. I, DENIESE C. CORNYHO, of legal age, Filipino Citizen, single and resident at No. 124 Purok 4, Cordita Compound, Brgy. San Juan, Surigao City, Surigao del Norte, after being duly sworn to in accordance with law, depose and attest: 1) That I am the petitioner in the above-titled case; 2) That I have caused the preparation of the foregoing petition and understood the contents thereof; 3) The allegations in the said complaint are true and correct according to my knowledge and belief; 4) Furthermore, I hereby certify that I have not filed nor caused to be filed any other similar case involving the same issues in the Supreme Court, Court of Appeals or any other tribunal or agency and that, should there be any other such case/s that may have been filed, I hereby bind myself to inform the Court of such fact within five (5) days from the discovery thereof. IN WITNESS WHEREOF, I have hereunto affixed my signature this 13 day of February 2014, City of Surigao, Surigao del Norte, Philippines.
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DENIESE C. CORNYHO Affiant CTC No. 6901069


Issued On: 01/20/2014, Surigao City

SUBSCRIBED AND SWORN to before me, in the City of Surigao, this 13th day of February 2014, City of Surigao, Surigao del Norte, Philippines, affiant having exhibited to me his Drivers License No. 010010, issued at Surigao City, Philippines. ATTY. WAY A. KASO Notary Public Until December 31, 2014 PTR No. A-123056
Issued at Surigao City on 01/01/ 2013
Doc. No. 1; Page No. 1;

Book No. 1; Series 2014.

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