1

Republic of the Philippines
Ninth Judicial Region
Municipal Trial Court
xxxx City, Branch 3

Artemio Perez, Enrique Perez,
and Mariano Perez, All Minors,
assisted by Juanita Perez, guardian
Plaintiffs,
Civil Case No. 5678
- versus -

For: Breach of Contract

Martha Ferrer,
Defendant
x ----------------------------------------------- x

COMPLAINT
COMES NOW, the plaintiff through undersigned counsel to
this Honorable Court, most respectfully states that:
1. Plaintiffs are all minors assisted by Juanita Perez, their
guardian, the latter of legal age, Filipino, widow, all residents of
Camino Nuevo, Zamboanga City, Philippines.
Defendant is a Filipino, of legal age, single, resident of
Tetuan, Zamboanga City, Philippines, also the mother of the
plaintiffs-minor children.
2. Plaintiffs and defendant are co-owners of a house and lot
located at 123 Camanchile Drive, Zamboanga City, Philippines,

4.2 donated by Rolando Perez. A copy of the Deed of Donation is herein attached as Annex A. the plaintiff. 13 August 2015 . Sometime in January 2011. Zamboanga City. Two years later. being the mother of the co-owners. After the execution of the mortgage contract by and between the defendant and mortgagee-bank. Other just and equitable reliefs are also prayed for. defendant left for abroad. they were informed by the mortgageebank that the same are subject to foreclosure. while plaintiffs are possessing and occupying the premises. 6. from whom the parties descended and traced their claim of ownership and right of possession. 3. Due to defendant’s breach of trust in the management of the co-owned properties. compensatory and nominal damages. premises considered. plaintiff respectfully prays that judgment be rendered ordering defendant to pay the plaintiffs moral. the father of the plaintiffs-minor children. The defendant. 5. 7. signed for and on behalf of the minors. WHEREFORE. Juanita Perez. on behalf of the minor children. and Attorney’s fees. leaving the custody of her children to herein plaintiff. A copy of the Contract of Mortgage is attached as Annex B. the defendant mortgaged the said properties to secure her personal loan. to the detriment of the rights and interests of the minor co-owners over the said properties. to consent such disposition. is constrained to secure the services of counsel and file this complaint.

3. or quasijudicial agency. of legal age. and that the same and true and correct of my personal knowledge and/or based on authentic records. Zamboanga City. That I have read the allegations therein contained. 2. That I have caused the preparation of said complaint. and to the best of my knowledge. after having been duly sworn to under oath. and a resident of Camino Nuevo. . 4.3 Counsel for plaintiff La Purisima Street. That I have not theretofore commenced any action or filed any claim involving the same issues in court. I shall report that fact within five (5) days therefrom to the Court wherein the aforesaid complaint or initiatory pleading has been filed. Juanita Perez. Philippines. and if I should thereafter learn that the same or similar action or claim has been filed or is pending. Zamboanga City Philippines VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING I. tribunal. depose and say: 1. widow. That I am the plaintiff in the above entitled complaint. no such other action or claim is pending therein.

2015 . Philippines. this thirteenth day of July 2015. affiant appearing before me with her CTC No. 2015. 123456789-0 issued on January 10. Notary Public Until December 31. and who signed said document in my presence and sworn as to said document that she understood the contents thereof and that the same was his free and voluntary act and deed. Philippines. a notary public. Juanita Perez Affiant SUBSCRIBED AND SWORN to before me. at Zamboanga City.4 Witness my hand this 13th of August 2015 at Zamboanga City.

5 Doc. 01 Book No. No. I Series of 2015 . 02 Page No.

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