Complaint 1
Complaint 1
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COMPLAINT
THE PARTIES
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St., Dizon Subdivision, Baguio City, where he may be served with summons
and other court processes.
Classification: Area:
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Commercial lot : 59 sq. m.
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“D” Tax Declaration To prove the assessed value of the
property in the Deed of Real Estate
mortgage.
PRAYER
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2. Issuing a decree of foreclosure for the sale at public auction of the
above-described real property, together with all improvements existing
thereon, and for the disposition of the proceeds thereof in accordance with
law and the Rules, upon failure of the defendants to pay the plaintiff as
above set forth;
3. Ordering the defendants to pay unto the plaintiff the costs of suit.
Plaintiff prays for such other relief and remedies just and equitable in the
premises.
RESPECTFULLY SUBMITTED
Baguio City, March 28, 2023.
By:
KennAngala
Atty. Kenn Jaero Angala
09177165444 | [email protected]
Roll of Attorneys No. 100001
IBP Lifetime No. 09821
PTR No. 12312532/02-01-2023/Baguio City
CleahMaryellLlamas
Atty. Cleah Maryell Llamas
09173431682 | [email protected]
Roll of Attorneys No. 100012
IBP Lifetime No. 09224
PTR No. 12123522/02-01-2023/Baguio City
XyrusFlores
Atty. Raziel Xyrus Flores
09179023524 | [email protected]
Roll of Attorneys No. 100221
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IBP Lifetime No. 09991
PTR No. 12234532/02-01-2023/Baguio City
Copy furnished:
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VERIFICATION AND CERTIFICATION
OF NON-FORUM SHOPPING
3. I have read and understood the contents thereof and the facts
alleged therein are true and correct based on my personal
knowledge and/or on the basis of copies of documents and records
in my possession;
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SUBSCRIBED AND SWORN to before me this 3rd day of
December 2022, in the City of Baguio affiant personally appearing before
me and exhibiting to me his valid PRC ID representing to me that he is one
and the same person who executed the foregoing.
JJL
Jezreel John Llanes
Notary Public for the City of Baguio
Until December 31, 2023
Commission Serial No. NP-2023-01
Roll of Attorney No. 82132, January 02, 2021
IBP Receipt No. 68612; 12-06-2023; Baguio City
PTR No. 2132132, 12-06-2023; Baguio City
MCLE Compliance No. V-918272 valid until March 09, 2023
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ANNEX “A”
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ANNEX “B”
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ANNEX “C”
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ANNEX “D”
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ANNEX “E”
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ANNEX “F”
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