Vergara Complaint
Vergara Complaint
COMPLAINT
1. That the plaintiffs Roweno Zaragoza and Eliseo Vergara, are both of
legal ages, Filipino citizens and residents of dagupan Lal-lo Cagayan
and Cento Sur, Alcala Cagayan, respectively;
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A copy of the Deed of Confirmation of Absolute sale is hereto
attached as Annex B;
5. That after the sale, plaintiff Zaragoza delivered the original duplicate
copy of Transfer Certificate of Title No. 23180 to his co-plaintiff
Vergara;
8. That defendants prepared a Deed of Sale dated June 16, 2014, forged
the signature of plaintiff Zaragoza thereon and had it notarized and
acknowledged before Atty. Edgar Orro, Notary Public for and in the
Province of Cagayan and entered in the latter’s Notarial registry Book
as Doc. No. 1330, Book No 266, Page no. 1 and series of 2014.
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name of defendant L.R Developer’s Incorporation using the falsified
Deed of Sale;
14. That under the law, land awarded to farmer beneficiaries under the
agrarian reform may only be transferred to another qualified farmer
beneficiary after the payment of the purchase price and lapse of
prohibitory period of 10 years. Thus, by any stretch of human
imagination, the subject land can never be transferred to defendant
corporation as the said corporation is not a “qualified farmer
beneficiary” lest a natural person capable of cultivating the subject
land.
16.That to cite the defendants as an example for good of the public and to
forestall other individuals from acting in a similar manner, exemplary
damages at no less than P30,000.00 must be awarded to the plaintiffs;
17.That to aid plaintiffs in the recovery of the property, they have been
compelled to secure the services of counsel whose fees are agreed
upon in the amount of P50,000.00.
a. Ordering the annulment of the Deed of Sale dated June 16, 2014;
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c. Ordering the defendants to pay exemplary damages in the amount of
P30,000.00; and
Plaintiff further prays for such other reliefs and remedies deemed just
and proper under the premises.
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VERIFICATION AND CERTIFICATION OF NON-FORUM
SHOPPING
3. We have read the contents thereof and the facts stated therein are true and
correct of our personal knowledge and/or on the basis of copies of
documents and records in my possession;
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Page No. ;
Book No. ;
Series of 2019