Forcible Entry Complaint

Republic of the Philippines
MUNICIPAL TRIAL COURT IN CITIES

Second Judicial Region
Santiago City
Alexeus B. Del Mundo, Civil Case No. 1234

Plaintiff, For: Forcible Entry
- Versus -
Spouses Jose C. Manuel

and Jenny D. Manuel,
Defendants.
x-------------------------------x
COMPLAINT
COMES NOW, the plaintiff through the undersigned counsel and unto this
Honorable Court, most respectfully states that;
1. The plaintiff is of legal age and resident of No. 75, Quirino St. Brgy.
Balintocatoc, Santiago City. The defendants are likewise of legal age,
married and residing at Brgy. Balintocatoc, Santiago City.
2. The Plaintiff is the owner of the parcel of land located at No. 75,
Quirino St., Brgy. Balintocatoc, Santiago City, with an area of 10, 600
square meters and covered by TCT No. RP-175 (FP-13 787), herein
attached as “ANNEX A”, and Tax Declaration No. 157-0011-002549,
herein attached as “ANNEX B”;
3. That the plaintiff and his family have been living and is in possession
of the said property for more than thirty years up to the present and in
fact have constituted thereon their family home as attested by two
witnesses who are the neighbors of the plaintiff since they moved in the
said property, herein attached as “Annex C and D”;
4. That the whole area of the said property is secured and fenced by
concrete poles and barbed wires;
5. That no other persons other than the plaintiff and his family is in actual
possession of the subject property for the past thirty years;
Page 1 of 3
6. That on January 30, 2019, the plaintiff, upon his return from a one week
vacation in Bohol with his whole family and while doing his regular
inspection of his property, was surprised when he saw that in the north
portion of the said land was a broken fence and a shanty house already
erected and occupied by the defendant spouses, unlawfully depriving
the plaintiff of the actual possession of his property through force and
stealth;
7. That the plaintiff asked the defendant spouses to leave the premises but
they vehemently refused to do so which compelled the plaintiff to
immediately inform the Barangay officials of the said unlawful
intrusion by the defendants;
8. That the plaintiff and the defendants went through a barangay

conciliation but the parties failed to reach a settlement agreement as
evidenced by a Barangay Certificate to File Action, herein attached as
“Annex E”;
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that judgment be rendered in favor of the plaintiff, directing
the following;
a. The defendant shall vacate property owned by the plaintiff.
b. The defendant shall be ordered to pay P 120, 000 for Attorney’s

Fees.
Such other reliefs and remedies under the premises are likewise prayed for.
Santiago City, Philippines, this 19th day of February, 2019.
Atty. Belle Jane B. Santos

Counsel for the Plaintiff
PTR No. 18909595:1-04-07:S.C.
IBP No, 693095:1-04-07:S.C.
Roll No. 42481:5-10-97: Manila
Rm. 4 2/F Santiago Pagibig Building
180 Malvar, St. Santiago City
Page 2 of 3
VERIFICATION AND CERTIFICATION
I, Mr. Alexeus Del Mundo, of Legal age, married, Filipino Citizen and a
resident of No. 14 Valentines St., Lovely Subdivision, Brgy. Balintocatoc,
Santiago City, after being sworn according to law, hereby depose and state
that;
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of
documents and records in my possession;
4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;
5. To the best of my knowledge and belief, no such action or proceeding

is pending in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has been

filed or is pending before the Supreme Court, the Court of Appeals, or
any other tribunal or agency, I undertake to report that fact within five
(5) days therefrom to this Honorable Court.
Alexeus B. Del Mundo

Complainant
Subscribed and sworn to before me this ______day of February 19,

2019, at Santiago City, personally appeared __________________________,
with Residence Certificate No. _______ issued at ___________, on _______,
and BIR Tax Account No. __________ known to be the same person who
executed the foregoing instrument, and he acknowledge to me that the same
is his free act and deed
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my

notarial seal, the day, year, and place above written.
Notary Public
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Forcible Entry Complaint

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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Alexeus B. Del Mundo, Civil Case No. 1234

Spouses Jose C. Manuel

8. That the plaintiff and the defendants went through a barangay

WHEREFORE, premises considered, it is most respectfully prayed of this

a. The defendant shall vacate property owned by the plaintiff.

b. The defendant shall be ordered to pay P 120, 000 for Attorney’s

Santiago City, Philippines, this 19th day of February, 2019.

Atty. Belle Jane B. Santos

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

4. I have not commenced any other action or proceeding involving the

5. To the best of my knowledge and belief, no such action or proceeding

6. If I should thereafter learn that a similar action or proceeding has been

Alexeus B. Del Mundo

Subscribed and sworn to before me this ______day of February 19,

IN WITNESS WHEREOF, I have hereunto set my hand and affixed my

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