Preliminary Injunction

Regional Trial Court
National Capital Judicial Region

METROPOLITAN TRIAL COURT
Quezon City
Branch ___,
ROB BARATHEON,
Plaintiff,
Civil Case No. ______
- versus - For : FORCIBLE ENTRY
WITH PRAYER FOR
ISSUANCE OF WRIT OF
PRELIMINARY
INUNCTION
GEOF LANNISTER,
Defendant.
x ----------------------------------- x
COMPLAINT
PLAINTIFF, by counsel, respectfully states that:
1. Plaintiff is a Filipino of legal age, married and a resident of 5 Storm Street,

Barangay Lupa, Quezon City; while Defendant is a Filipino, of legal age, single and
currently resident of 23 Kings Street, Landing Compound, Quezon City, where he may be
served with summons and other pertinent processes.
2. Plaintiff owns that property located at 23 Kings Street, Landing Compound,

Quezon City identified as Cadastral Lot No. 236 Gs 1189 (Lot 236 henceforth) with an
area of 37, 185 square meters, more or less. Attached as Annex “A” is a copy of Tax
Declaration No. 12093 and made integral part hereof. Also attached as Annex “B” is a
machine copy of Official Receipt No. 1874594-A and made integral part hereof.
3. Plaintiff have been in possession over the said parcel of land for more than 30
years including that of his predecessor in interest and that his ownership is open, public
and continuous and the same is free from claims and conflict.
4. Realizing that Lot 236 could be lucrative, plaintiff thought of capitalizing on

the lot. Plaintiff decided to engage in the business of Sand and Gravel.
5. On September 7, 2017, plaintiff introduced improvements by building two

small houses made of galvanized sheets which were intended as shelters for him and his
workers. In the same month of the same year, plaintiff and his friends had a picnic at the
subject lot. Attached as Annex “C” and series are photos of said improvements.
6. Sometime in the third week of October 2017, the defendant took advantage of
the night time and forcibly entered the premises and installed barbed wires fenced with
concrete post.
7. When the plaintiff went to inspect the subject premises, he found that the small
houses which he built that served as a shelter and stock room were demolished.
8. From then on, the plaintiff can no longer possess and utilize the subject lot
because the defendant had the area guarded.
9. Plaintiff filed a complaint before the Barangay Lupon but the same was futile
as the parties failed to come up with a compromise agreement. Attached as Annex “D” is
a Certificate to File Action dated Marcy 29, 2018 signed by CORNELIO D. DUMALOY,
the Punong Barangay of Barangay Agat, Municipality of Sison, Province of Pangasinan.
ALLEGATIONS IN SUPPORT OF THE PRAYER

FOR THE ISSUANCE OF A WRIT OF PRELIMINARY
INJUNCTION
10. Petitioner incorporates fully and by this specific reference the statements in
paragraphs 1 to 10 of the complaint as if fully stated herein.
11. Defendant therefore must be restrained from committing continuous acts that
leads to the dispossession of the land of the petitioner and there is immediate need to
compel them to vacate the property.
12. The acts of the defendants in unlawfully withholding the land from the
petitioner during the pendency of the present case shall work injustice to the petitioner.
13. Petitioner suffered and is continuously suffering much damage due to the
unlawful acts of defendant as at the time he learned the forcible entry of the defendant to
his land, he is already in the process of developing to the lot in question considering the
fact that the location of which is near the national highway.
14. However, due to the act of the defendant, petitioner, until present have not
started developing the premises and is therefore much prejudiced as they have already
started introducing improvements such as two small houses which they find beneficial to
them but they could not utilize due to the acts of the defendant.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed that the

Honorable Court GRANTS the following relief:
1. ISSUE a Preliminary Injunction to prevent the defendant from conducting

activities prejudicial to the interest of the Petitioner.
2. DIRECT the respondent to permanently VACATE the subject lot and give the
rightful possession to the plaintiff;
3. DIRECT the respondent to PAY attorney's fees in the amount of _________ to

the plaintiff, and pay the cost of suit.
4. Other just and equitable reliefs are also prayed for.
May __, 2018. Quezon City
REYNALDO CORTES LAW OFFICE

Counsel for the Petitioner
Room 307, Jose Miguel Building
No. 1 Labsan St., Quezon City
By:
VERIFICATION/CERTIFICATION
I, ROB BARATHEON, of legal age, Filipino citizen, married, and a resident of 5

Storm Street, Barangay Lupa, Quezon City after having been duly sworn to in accordance
with law, hereby depose and say that:
1. I am the complainant in the above-entitled case;
2. I caused the preparation and filing of this Complaint;
3. I read the contents of the foregoing pleading and everything contained therein
are true and correct according to my own personal knowledge and based on
authentic records;
4. I have not commenced any other action or proceeding involving the same
issues before the any court, tribunal or agency;
5. I further certify that no such action or proceeding is pending before any court,
tribunal or agency; and
5. If I should thereafter learn that a similar action of proceeding has been filed or
is pending before any court, tribunal or agency, I hereby undertake to notify this
Honorable Court within five days from notice thereof.
IN WITNESS WHEREOF, I have hereunto set my hand this ___day of May,
2018 at Quezon City, Philippines.
ROB BARATHEON
Affiant
SUBSCRIBED AND SWORN to before me this ___ day of May in the City of
Quezon Philippines.
Doc. No : ___
Page No: ___
Book No: ___
Series of 2018
Copy furnished by registered mail:
GEOF LLANISTER
Respondent

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Regional Trial Court

National Capital Judicial Region

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino of legal age, married and a resident of 5 Storm Street,

2. Plaintiff owns that property located at 23 Kings Street, Landing Compound,

4. Realizing that Lot 236 could be lucrative, plaintiff thought of capitalizing on

5. On September 7, 2017, plaintiff introduced improvements by building two

ALLEGATIONS IN SUPPORT OF THE PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that the

1. ISSUE a Preliminary Injunction to prevent the defendant from conducting

3. DIRECT the respondent to PAY attorney's fees in the amount of _________ to

4. Other just and equitable reliefs are also prayed for.

May __, 2018. Quezon City

REYNALDO CORTES LAW OFFICE

I, ROB BARATHEON, of legal age, Filipino citizen, married, and a resident of 5

Copy furnished by registered mail:

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