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    Complaint With Prelim Injunction

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    Czarina Rubica
    The plaintiff filed a complaint against the defendant for recovery of possession of a parcel of land. The plaintiff allowed the defendant to temporarily shelter on the land. However, in 2005, the defendant began constructing a concrete house without the plaintiff's consent. Despite demands, the defendant refused to stop construction. The plaintiff is requesting a preliminary injunction to stop construction as well as monetary damages for moral damages, exemplary damages, and attorney's fees totaling P252,500.

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    Complaint With Prelim Injunction

    Uploaded by

    Czarina Rubica
    142 views3 pages
    The plaintiff filed a complaint against the defendant for recovery of possession of a parcel of land. The plaintiff allowed the defendant to temporarily shelter on the land. However, in 2005, the defendant began constructing a concrete house without the plaintiff's consent. Despite demands, the defendant refused to stop construction. The plaintiff is requesting a preliminary injunction to stop construction as well as monetary damages for moral damages, exemplary damages, and attorney's fees totaling P252,500.

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    complaint with prelim injunction

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    The plaintiff filed a complaint against the defendant for recovery of possession of a parcel of land. The plaintiff allowed the defendant to temporarily shelter on the land. However, in 2005, the defendant began constructing a concrete house without the plaintiff's consent. Despite demands, the defendant refused to stop construction. The plaintiff is requesting a preliminary injunction to stop construction as well as monetary damages for moral damages, exemplary damages, and attorney's fees totaling P252,500.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    142 views3 pages

    Complaint With Prelim Injunction

    Uploaded by

    Czarina Rubica
    The plaintiff filed a complaint against the defendant for recovery of possession of a parcel of land. The plaintiff allowed the defendant to temporarily shelter on the land. However, in 2005, the defendant began constructing a concrete house without the plaintiff's consent. Despite demands, the defendant refused to stop construction. The plaintiff is requesting a preliminary injunction to stop construction as well as monetary damages for moral damages, exemplary damages, and attorney's fees totaling P252,500.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    REPUBLIC OF THE PHILIPPINES

    REGIONAL TRIAL COURT

    City of ________

    Branch ____

    Mr. X

    Plaintiff

    -versus- CIVIL CASE NO. _________

    For: Recovery of possession


    with prayer for the issuance
    of a writ of preliminary
    injunction and/or Temporary
    Restraining Order

    Mr. Y

    Defendant

    x--------------------------x

    COMPLAINT

    COMES NOW, the plaintiff, through the undersigned counsel, and to


    this Honorable Court, respectfully alleges:

    1. That the plaintiff is of legal age, Filipino citizen, with address at


    ______________________________;

    2. That the defendant is of legal age, Filipino citizen, with postal


    address at _________________________________, where he may be
    served with summons and other processes by this Honorable Court;
    3. That the plaintiff is the registered owner of a parcel of land
    located in Pasig City covered by the Transfer Certificate of Title No. ____
    issued by the Register of Deeds of Pasig City;

    4. That sometime on December 2, 2000, the defendant asked the


    plaintiff if he can stay in the premises of the plaintiff to use it as a temporary
    shelter, and the latter agreed for humanitarian consideration;

    5. That on May 2005, without the consent of the plaintiff, the


    defendant started to build a concrete house over the premises of the
    plaintiff, and the latter demanded the construction be stopped, but the
    defendant refused to accede to the demands of the plaintiff;

    6. That despite oral and written demand, the defendant still


    refused and continuously refuses to stop the construction of the said
    house, to the damage and prejudice of the plaintiff;

    7. That as a consequence of the illegal acts of the defendant, the


    plaintiff suffered sleepless nights, serious anxiety in which he should be
    awarded the amount of P100,000 as moral damages, and to set an
    example to the public he should be awarded exemplary damages in the
    amount of P100,000;

    8. That the plaintiff was forced to litigate and engage the services
    of a counsel in the amount of P50,000 as attorney’s fees, and appearance
    fee of P2,500 for every hearing of the case.

    WHEREFORE, premises considered, it is most respectfully prayed of


    this Honorable Court that judgment be rendered:

    a) That, upon plaintiff filing a bond in an amount which this


    Honorable Court may fix, a writ of preliminary injunction be immediately
    issued, restraining and enjoining to defendants from continuing the
    construction of a house over the plaintiff’s premises;

    b) That, after trial, judgment be rendered making said preliminary


    injunctions permanent, and ordering the defendant to pay the sum of
    P100,000 as moral damages, P100,000 as exemplary damages, and
    P50,000 as attorney’s fees.

    Such other relief and remedies as may be deemed just and equitable
    under the premises are likewise prayed for.

    Manila, May 31, 2019.

    Czarina Letecia E. Rubica

    IBP No. ____

    PTR No. ___

    Roll No. ____

    VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

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