Republic of the Philippines
REGIONAL TRIAL COURT
7th Judicial Region
CHARLES PO, BRUNO PO and
Civil Case No. 42345
For: RECONVEYANCE AND/OR RECOVERY OF
OWNERSHIP AND POSSESSION, CANCELATION
OF TITLE, AND DAMAGES
EUMA CARREON, SPS. JERRY and
KARA S. CARREON,
SPS. JEROME and INA CARREON
CO MPLAI NT
COME NOW, Plaintiffs through their undersigned counsel and to this Honorable Court, most respectfully allege that:
1Parties to the case:
Plaintiff's name, age, citizenship, status, residency.
Defendant's name ,age, citizenship, status, residency.
2Statement of facts
3Cause of action
WHEREFORE, it is respectfully prayed of this Honorable Court that after due notice and hearing, judgment be rendered as follows:
Plaintiff prays for such other reliefs as may be just and equitable in the premises.
City of Cebu, Philippines, 27th of June 2015.
ATTY. YDREL OBSIOMA
Counsel for the Plaintiffs
507 S. Osmena St., Gun-ob, Lapu-Lapu City
Roll of Attorneys No. 84262
IBP No. 534532/01-03-2015/CEBU CITY
PTR No. 467221/01-02-2015/CEBU CITY
MCLE Cert No. 83192, issued on Oct 15, 2015
Mobile No. 0928-5017536
Email Address: firstname.lastname@example.org
VERIFICATION AND CERTIFICATION OF
NON – FORUM SHOPPING
I, CHARLES PO, Filipino, of legal age residing at Unit D1, Ponce Building, Mabolo, Cebu City, after being sworn to in
accordance with law, deposes and says that:
I am the Plaintiff in the above-entitled case;
The facts stated in the above complaint are true and correct to the best of my knowledge and authentic records;
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 suck other action or claim is pending in them; and
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 comlplaint or initiatory pleading has been filed.
IN WITNESS WHEREOF.000.000. it is respectfully prayed of this Honorable Court that after due notice and hearing. 2015 in Cebu City.00) PESOS. That DEFENDANTS admit the averment in paragraph 1 of the Complaint as far as the Plaintiff’s personal circumstances are
concerned.) Ordering Plaintiffs to pay to Defendants.
3. DEFENDANTS as absolute owner of the questioned property exercised his right to dispose of the same as absolute owner
ANSWER WITH COUNTERCLAIM
Comes Now. 2014 at the Pasay City.000. Defendants in the above entitled case and to this Honorable Court most respectfully avers.
WHEREFORE.P2.00 deposit for legal expenses.
Currency.00 per Appearance.
PLAINTIFFS herself signed the deed of sale (ANNEX “A”) in favor of the DEFENDANTS as evidenced by a photo was taken during the
signing of the deed of sale where both PLAINTIFF and DEFENDANTS were present. jointly and severally the sum of FIFTY THOUSAND (P50. to wit:
ADMISSIONS AND DENIALS
SUBSCRIBED and SWORN to before me. 123456 issued on September 16. PLAINTIFFS voluntarily.00) PESOS. P5. willfully and freely executed a deed of sale on her own accordance in favor of DEFENDANTS. That DEFENDANTS admit the averment in paragraph 2 insofar as deef of absolute sale was executed by Plaintiff in favor of
DEFENDANTS. Philippine Currency. PLAINTIFFS had executed a valid absolute deed of sale in favor of DEFENDANTS in the exercise of her rights to donate the
property to other persons.) Ordering Plaintiffs to pay to Defendants.) Ordering Plaintiffs to pay to Defendants. That such donation was likewise recorded in the Land Registry of Cebu. jointly and severally. Cebu
. judgment be rendered as follows:
1. jointly and severally litigation expenses incurred by Plaintiffs and costs of this suit. by way of Acceptance fee.
DEFENDANTS respectfully restate all foregoing allegations and denials and hereby further state that:
1.000. the aforesaid sum of ONE HUNDRED THOUSAND
Defendants hereby restates all foregoing allegations and further state that:
1. this 27 th day of June 2015. DEFENDANTS had lawful possession and ownership of the property donated by PLAINTIFFS and such rights the plaintiff had
were transferred to defendants upon registration and issue of the Transfer Certificate of Title in favor of defendant. in the City of Cebu by Charles Po with Passport
No. by way of actual and/or compensatory damages. I have hereunto affixed my signature this 4th day of September.
Brgy. Euma Carreon. YDREL OBSIOMA
Counsel for the Plaintiffs
507 S. are hereby specifically denied the truth of the matter
being those stated in the Complaint. for reasons
stated in the complaint. the answering defendants claim is without any legal or factual basis. 84262
IBP No. through the undersigned counsel and to this
Answer with Counterclaim –
Honorable Court. 83192. Osmena St. Gun-ob.. 30th of July 2015.2015 Issued on: May 2.2015
Issued at: GSIS CEBU Issued at: SSS CEBU
SUBSCRIBED AND SWORN to before me this 30th day of July 2015 in the City of Cebu.
We have read the foregoing petition and the allegations therein are true and correct of my own knowledge and/or based on the
records on hand. most respectfully submits this Reply to Defendant’s
Issued at: SSS CEBU
GSIS ID 321452
SSS ID 657332
Issued on: May 2. Jerome Carreon. Cebu City.
2. are hereby specifically denied.
That paragraph 3-6 of the Answer of the defendants Irene and Joy Velvet.
That the aforesaid acts of the answering defendants are malicious and have been done in utter bad faith and have been done in
utter bad faith. Moreover. Jerry Carreon. 534532/01-03-2015/CEBU CITY
That we. 2015
WHEREFORE. in derogation of the established legal rights of the plaintiff. Lapu-Lapu City
Roll of Attorneys No.
The allegations under the Counterclaim. containing their pictures and signature which they identified to me as the persons
who executed the foregoing verification.
and for the reason that the same are mere gratuitous conclusions on the part of the answering defendant. Therefore. Philippines. 2015
. issued on Oct 15.
SSS ID 412432
Issued on: May 2.
We attest to the authenticity of the annexes thereof. the Deed of Sale attached to the Answer is not legal.
Email Address: ydrel@yahoo. it is respectfully prayed unto this Honorable Court. Ina Carreon and Kara Carreon subscribe under oath.Defendants prays for such other reliefs as may be just and equitable in the premises.
City of Cebu. the ownership thereof belongs to the
plaintiff. 467221/01-02-2015/CEBU CITY
MCLE Cert No. hereby deposes
and states that:
We are the defendants in the instant case. dismiss the Counterclaim of the
defendants Irene and Joy Velvet and to grant the reliefs and remedies prayed for in the Complaint.
PLAINTIFF. the truth of the matter being those stated in the complaint. premises considered. Philippines
JUDICIAL AFFIDAVIT OF WITNESS
August 1. Basak. Philippines by the affiants mentioned
above with their respective competent evidence of identity.
Parian. 65544 issued
September 16. issued on Dec 11.com
Cellphone No. How did you know her?
Ans: We live in the same Barangay and she asked me if I can be the caretaker of her property because she was going to work abroad. How are you related to the plaintiff in this case?
Ans: She was my employer. How did you know the defendant?
Ans: I came to know the defendant when I was called by my boss to be a witness to the contract of lease they executed. year and place first above-written.
3.and (3) all matters related thereto. in English. Brgy. Ydrel Obsioma.
Questions were propounded by plaintiff’s counsel. 8111118. Lerdy Beck. and occupation. OBSIOMA
December 20. is executed to serve as his direct testimony in the instant case. 6969010. with reservation to present additional exhibits in the
course of the proceedings of the instant case. Please state your name. knowingly and intelligently executed the foregoing and that she fully
understands it contents. 09228218605
Roll No. I have hereunto affixed my signature this 14th day of August. 2015. which he respectfully requests to be
correspondingly marked as EXHIBITS in this case . affiant exhibiting to me her SSS ID No. Parian. while
Answeres were given/made by witness Mr.
This Judicial Affidavit is offered to prove:
(1) all the allegations in the complaint. 2014
PTR No. in English dialect and the corresponding translation of his answer is provided after
Ans: I am Lerdy Beck. on the day. issued on January 12. X-000069
IBP No. (2) including all the ANNEXES appended thereto. 2015 at Cebu City. Atty.
3. I hereby certify she has voluntarily.
YDREL C. this 14th day of August . age. 2014 at Cebu City.
2. Cebu City.
N WITNESS WHEREOF.
WITNESS MY HAND AND NOTARIAL SEAL.This Judicial Affidavit of Lerdy Beck. Cebu City. 014040001
MCLE Compliance Certificate No.
SUBSCRIBED AND SWORN to before me.
Ans: The defendant is the lessee of the property situated at Zamora St.
1. residence address. 42 years old. 2015
ydrel@yahoo. which the affiant fully understands. I live in Brgy.