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Possession

1. The complaint alleges that Mrs. Squatter occupied the plaintiff's titled lot for over a year without permission. 2. The plaintiff, Abigail G. Mallari, provides documentation showing she is the registered owner of the property including the title, tax declaration, and tax receipts. 3. Mrs. Squatter built a small house on the property and refuses to vacate despite demand letters. The plaintiff is seeking a preliminary mandatory injunction ordering Mrs. Squatter to vacate the property and payment for unjust enrichment and damages.

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Princess Pilove Gawongna
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33 views2 pages

Possession

1. The complaint alleges that Mrs. Squatter occupied the plaintiff's titled lot for over a year without permission. 2. The plaintiff, Abigail G. Mallari, provides documentation showing she is the registered owner of the property including the title, tax declaration, and tax receipts. 3. Mrs. Squatter built a small house on the property and refuses to vacate despite demand letters. The plaintiff is seeking a preliminary mandatory injunction ordering Mrs. Squatter to vacate the property and payment for unjust enrichment and damages.

Uploaded by

Princess Pilove Gawongna
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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1.

Prepare the following pleadings:


a. Assume that your titled lot was occupied for more than a year by a certain Mrs.
Squatter. Prepare a Complaint for Recovery of Possession, Ownership and damages:

Republic of the Philippines


DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
Office of the Provincial Prosecutor
Cabarroguis, Quirino

ABIGAIL G. MALLARI,
Complainant,

-versus- II-05-INV-______________
For: Recover possession of real property
MR. SQUATTER with prayer for preliminary
mandatory injunction

Respondent
x- - - - - - - - - - - - - - - - - - -x

AFFIDAVIT OF COMPLAINT

I, ABIGAIL G. MALLARI, Filipino, of legal age, single, and a resident of


Patul, Santiago City, after having been duly sworn to in accordance with the
law, do hereby depose and state, that:

1. I am the same person executing this affidavit of complaint;

2. I am the registered owner of a specific parcel of lot situated at Brgy.


Luttuad, Diffun, Quirino covered by Transfer Certificate of Title 100492 and
with area of 150 square meters (attached and marked as Annex “A”);

3. The latest Tax Declaration with number 017-001-0020 pertaining to the


aforementioned property shows that its assessed value is P1,700,000.00.
Described tax declaration also shows my name as the registered owner
(attached and marked as Annex “B”);

4. I have been paying the real property taxes of the subject parcel of land
since 2008 up to present as evidenced by copy the real property tax receipts
marked as Annex “C”;

5. Since I have no immediate need for the parcel of land and had no enough
money for the succeeding purpose, I was not able to build a fence around the
lot since the date I acquired the same;

6. It came to my knowledge that a certain Mr. Squatter has built a small


nipa house in my described lot and has been occupying the same for more
than a year now. Photos of the house herein referred to and the Affidavit of

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the informant, Mr. Whistleblower, attached and marked as Annexes “D” and
“E”, respectively;

7. Demand Letters were sent and duly received by the respondent last
February 15 of this year, but showed no intention of vacating the subject
parcel of land. (Receiving copy of the Demand Letter marked as Annex “D”);

8. In view of the foregoing, I am respectfully praying to the Honorable Office


of the Municipal Prosecutor to resolve that writ of preliminary mandatory
injunction be issued to the respondent ordering him to vacate and deliver to
me the parcel of land described in the paragraph 2 of this complaint. In the
same manner, I would like to sue the respondent and collect payment for his
unjust enrichment over my property and damages for the incremental fees I
have incurred relative to this complaint.

IN WITNESS HEREOF, I have hereunto affixed my signature above my


printed name this _________ day of August, 2020 at Cabarroguis, Quirino,
Philippines.

ABIGAIL G. MALLARI
Affiant-Complainant
I.D. No.: ____________

SUBSCRIBED AND SWORN to before me this _______ day of August, 2020


at Cabarroguis, Quirino. I HEREBY CERTIFY that I personally examined the
affiant and I am fully convinced that she understands and voluntarily
executed her affidavit of complaint.

Administering Officer

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