Republic of the Philippines

MUNICIPAL TRIAL COURT

Zamboanga City
Branch 04

KOBE BRYANT, Plaintiff,

-versus-

CIVIL CASE No. 619

For: EJECTMENT (FORCIBLE
ENTRY)

JOHN CENA 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, KOBE BRYANT, of legal age, a Filipino, is residing at #12 San Roque,
Zamboanga City, where he may be served with court order and other processes;
2. Defendant, JOHN CENA, of legal age, a Filipino, is a resident of #18 Santa Maria,
Zamboanga 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, JUAN TUTRI. (A copy of the Deed of Sale is hereto attached as Annex
A);
4. The parcel of land, situated in #21 Santa Maria, Zamboanga City, is covered by Transfer
Certificate of Title No. 123456 issued by the Register of Deeds of Zamboanga City and
is more particularly described, as follows:
(a one-storey house made of semi-concrete materials, of two bedrooms, a
common toilet. The land having an area of 120 sq. meters with fence of about 5 feet
made of concrete materials)
(Copy of TCT- 123456 is hereto attached as ANNEX B);
5. Herein Defendant, through stealth and strategy, occupied the parcel of land in question
and refuses to vacate the same despite repeated oral and written demands. (Copy of
the written demand is hereto attached as Annex C);

6. 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) 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
TWENTY THOUSAND PESOS (Php 20,000.00).

PRAYE R
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 Thousand Pesos (P20,000.00), by way of other litigation expenses;
and
c. Pay the cost of this suit.
Plaintiff prays for such other remedies and reliefs as may be deemed just and
equitable under the premises.

February 15, 2016. Zamboanga City, Philippines.

ATTY. JOSE P. RIZAL

Counsel for Plaintiff
Roll of Attorneys No. 1234567
IBP No. A-1234567
PTR No. A- 1234567
MCLE No. A-1234567
VERIFICATION AND CERTIFICATION AGAINST NON- FORUM SHOPPING
I,KOBE BRYANT, of legal age, 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, and hereby declare that all the allegations contained therein are true and
correct according to my knowledge and belief.
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 set our hand this 5th day of February
2016, Zamboanga City, Philippines.

KOBE BRYANT
Affiant
CTC No. 1234565
Issued On: December 18, 2015
Issued At: Zamboanga City
SUBSCRIBED AND SWORN to before me, in the City of Zamboanga, this 5th
day of February 2016, Zamboanga City, Philippines, affiant having exhibited to me his
Drivers License No. 1234567890, issued at Zamboanga City, Philippines.
ATTY. JOSE P. RIZAL
Counsel for Plaintiff
Roll of Attorneys No. 1234567
IBP No. A-1234567
PTR No. A- 1234567
MCLE No. A-1234567
Doc. No. 1;
Page No. 1;
Book No. 1;
Series 2012.

Republic of the Philippines

MUNICIPAL TRIAL COURT
ZAMBOANGA CITY
Branch 04

KOBE BRYANT, Plaintiff,

-versus-

CIVIL CASE No.619

For: EJECTMENT (FORCIBLE
ENTRY)

JOHN CENA, Defendant.

x- - - - - - - - - - - - - - - - - - - - - - - - x
ANSWER
COMES NOW THE DEFENDANT JOHN DOE, through the undersigned counsel,
and unto this Honorable Court most respectfully submits that:
1. DEFENDANT ADMITS the allegations in paragraph 1 and paragraph 2 of complaint
insofar as they relate to their personal circumstances;
2. DEFENDANT specifically DENIES the allegations in paragraph 5 since he was given
authority by JUAN TUTRI to occupy the land.

PRAYE R
WHEREFORE, the answering defendant, most respectfully pray for judgment:
1. Dismissing the complaint with costs against the plaintiff; and
2. The Defendants further pray for any and all relief and remedies fitting and proper under
the premises.
City of Zamboanga, February 16, 2016
ATTY. MAY PANALO
Counsel for Defendant
Roll of Attorneys No. A-123467

IBP No.A-1234567
PTR No. A-12345570
MCLE No. A1234571

VERIFICATION
I, JOHN CENA, Filipino, of legal age, and residing at #18 Santa Maria,
Zamboanga City, after having been duly sworn in accordance with law, hereby depose
and state that:
1. I, the defendant in the present case, caused the preparation of the foregoing Answer;
2. that I have read and understood the contents thereof and that the same are true and
correct as to the best of our knowledge and belief.
City of Zamboanga, February 16, 2016

JOHN CENA
Defendant
CTC No. B-124843
Issued at Zamboanga City
On February 7, 2016

SUBSCRIBED AND SWORN to before me, in the City of Zamboanga, this 7th
day of February 2016, Zamboanga City, Philippines, affiant having exhibited to me his
Drivers License No. 1234780, issued at Zamboanga City ,Philippines.

ATTY. RONDA ROUSEY

Counsel for Defendant
Roll of Attorneys No. A-123467
IBP No.A-1234567
PTR No. A-12345570
MCLE No. A1234571

Copy furnished:

ATTY. RONDA ROUSEY

Zamboanga City