Professional Documents
Culture Documents
IYA ARELLANO,
Plaintiff,
X----------------------------------------X
C O M P L A I N T
Plaintiff, by and through the undersigned Counsel unto the Honorable Court, states:
1. Plaintiff is of legal age, Filipino, single, and a resident of #74 Rimando Road,
Aurora Hill, Baguio City;
3. Plaintiff is the owner of a parcel of land covered by Tax Declaration No. 12345,
declared under her name, and located at #12 Maria Basa Compound, Baguio City,
a copy of said Tax Declaration is hereto attached as Annex “A” and made an
integral part hereof;
7. Up to the present time, Defendant and their workers are continuously constructing
the fence on the aforesaid property against the will of the Plaintiff, in blatant
violation of the right of the Plaintiff;
8. The aforesaid act of the Defendant, if not restrained, would work injustice to the
Plaintiff;
9. The Plaintiff hereby applies for a Writ of Preliminary Injunction to restrain the
Defendant from the act herein complained of, and for this purpose hereby offers a
bond in such sum as this Honorable Court may fix;
11. In order to deter Defendant and other persons from their ilk in performing similar
malicious acts, Defendant should be assessed the amount of P 50,000.00 as and by
way of exemplary damages;
12. And finally, in filing this action in order to seek redress for her grievances and
recover damages, plaintiff was compelled to engage the services of the
undersigned Counsel for an agreed fee of P 20,000.00 as and by way of
acceptance fee plus the sum of P1,500.00 as and by way of appearance fee for
each attendance in court during trial.
PRAYER
c. Costs.
d. Other reliefs, just and equitable under the premises, are likewise prayed for.
Respectfully submitted this 11th day of January 2014, in the City of Baguio.
I, IYA ARELLANO, of legal age, single, Filipino citizen, and a resident of #74
Rimando Road, Aurora Hill, , Baguio City, hereby declare under oath that:
1. I am the plaintiff in the Civil Case Number 3479 for Forcible Entry; I have caused the
preparation of the foregoing complaint; I have read and understood the contents of the same;
and that all the allegations therein are true and correct of my own knowledge and based on
authentic documents;
a. I have not commenced any proceeding involving the same issues before the Supreme
Court, Court of Appeals, or any other Government Agency or Tribunal;
b. To the best of my knowledge, no such action is pending before the Supreme Court,
Court of Appeals, or any other Government Agency or Tribunal;
c. If there be any similar action before the Supreme Court, Court of Appeals, or any
other Government Agency or Tribunal, I undertake to report the same within five (5)
days to the court where the original action and certification referred to herein has
been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 31st day of January 2014,
in the City of Baguio, Philippines.
IYA ARELLANO
Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 31st day of January
2014 by IYA ARELLANO, personally known to me, who is the same person who personally
signed before me the foregoing affidavit and acknowledged that she executed the same.
JO-ANNE M. VENTIGAN
Notary Public for Baguio City
Until December 31, 2014
4F La Azotea Bldg., Session Road, Baguio City
Tel No.: (074)-442-3396
PTR No. 22222; 1/07/2012; Baguio City
IBP OR No: 7654321; 1/07/2012; Baguio City
Roll No.: 82112; 4/08/2004
Commission Serial No.: 74-NC-12 (R)
MCLE Compliance No.: IV-34458; 04/28/2012
TIN No: 802-112-107