Complaint With Prayer For Injunctive Relief

Republic of the Philippines
REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 43
City of Manila
United Alloy Philippines Corporation (Unialloy),

As represented by Mr. X, as the General Manager
Plaintif
-versus- Civil Case No. 12345
For: Recovery of possession
with prayer for issuance of
Writ of Preliminary Injunction
and/or Temporary Restraining
Order
Mario Mercedes
Defendant
x------------------------------------------------x
COMPLAINT
COMES NOW, the plaintif, through the undersigned attorney, and

this Honorable Court respectfully alleges:
1. That plaintif is a domestic corporation duly incorporated and

organized under Philippines laws, with principal office at Doa
Esperanza Building, Maceda Street, Sampaloc, Manila;
2. That defendant Y, is of legal age, Filipino citizen, with postal

address at No. 24 Evangelista Street, Santolan, Pasig City, where
he may be served with summons and other processes by this
Honorable Court;
3. That the plaintif is the registered owner of a parcel of land

located in Pasig City covered by Transfer Certificate of Title No.
19008 issued by the Register of Deeds of Pasig City;
4. That sometime on October 2, 2011, defendant asked the plaintif

if he can stay in the premises of the plaintif to use it as his
temporary shelter and the plaintif agreed for humanitarian
consideration;
5. That on January 2012, without the consent of the plaintif,

defendant started to build a concrete house over the premises of
the plaintif, and the latter demanded the construction be
stopped, but the defendant refused to accede to the demand of
the plaintif of the plaintif;
6. That despite oral and written demand, defendant still refused

and continuously refusing to stop the construction of the said
house to the damage and prejudice of the said plaintif;
7. That plaintif was forced to litigate and engaged the services of a

counsel in the amount of P 50,000.00 as attorneys fees, and
appearance fee of P 3,000.00 for every hearing of the case.
Plaintif respectfully pleads the foregoing allegations in support
of his prayer for an injunctive relief.
8. For the preservation of the rights of the parties pending such

proceedings, in the light of the circumstances there is an
imperative necessity for the issuance of a writ of preliminary
injunction to enjoin or restrain the defendant from constructing
concrete house so as not to pre-empt this Honorable Court from
resolving and deciding the matters raised herein.
9. If the questioned acts are not enjoined, plaintif will sufer great
and irreparable damage and injury, and the instant case would
be rendered moot and academic.
10. Plaintif is willing to post a bond for the issuance of a writ

of preliminary injunction in the amount that this Honorable Court
may require for the purpose.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed

of this Honorable Court that judgment be rendered:
a) At the outset, plaintif most respectfully seek for the issuance of

temporary restraining order addressed to the defendant, their
subordinates and all persons acting under him to refrain from
erecting concrete house, buildings and any structure on the
subject premises.
b) That, upon plaintif filing a bond in an amount, which this Court

may fix, a writ of preliminary injunction be immediately issued,
restraining and enjoining the defendants, to stop the
construction of the house over the premises of the plaintif.
c) That, after trial, judgment be rendered making said preliminary

injunctions permanent, and ordering the defendant to pay the
sum of P 100,000.00 as exemplary damages, P 50, 000.00 as
attorneys fees.
d) That the subject property be reconveyed to the plaintif.
Such other relief and remedies as may be deemed just and

equitable under the premises are likewise prayed for.
Manila, March 18, 2012.
TAN LIBRANDA ONEZA

AND CEPILLO LAW OFFICE
Counsel of the plaintif
Suite 506 Don Santiago
Building,
1344 Taft Ave., Ermita, Manila
By:
FERDINAND A. TAN
IBP No. 875574/1-6-12
PTR No. 0419241/1-18-
12/Manila
Roll No. 38488
MCLE No. 3847, April 4, 2011
Tel. No. 354-78-40
VERIFICATION/CERTIFICATION AGAINST NON-FORUM SHOPPING
REPUBLIC OF THE PHILIPPINES )

CITY OF MANILA ) S.S
I, Mr. X, of legal age, Filipino citizen, married, after having been duly
sworn to in accordance with law do hereby depose and say:
1. That I am the plaintif in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint

and have read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my

own knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or

proceeding involving the same issues in the Supreme Court,
Court of Appeals or any other tribunal or agency;
5. That if I should thereafter learned that a similar action or

proceedings has been filed or is pending before the Supreme
Court, Court of Appeals or any other tribunal or agency, I hereby
undertake to report that fact within five (5) days therefrom to the
court or agency wherein the original pleading and sworn
certification is contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of

the foregoing facts and to comply with the provisions of Adm.
Circular No. 04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this

18th day of March 2012, in the City of Manila.
MR. X
SUBSCRIBED AND SWORN to before me, this 18th day of March, in

the City of Manila, affiant exhibiting to me his Passport No.
XX123456789 issued on January 7, 2012 at Cagayan de Oro City.
FERDINAND A. TAN
Notary Public for Manila
IBP No. 875574/1-6-12
PTR No. 0419241/1-18-
12/Manila
Roll No. 38488
MCLE No. 3847, April 4, 2011
Tel. No. 354-78-40
Doc. No. 11;

Page No. 22;
Book No. V;
Series of 2013

Complaint With Prayer For Injunctive Relief

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Republic of the Philippines

REGIONAL TRIAL COURT

United Alloy Philippines Corporation (Unialloy),

COMES NOW, the plaintif, through the undersigned attorney, and

1. That plaintif is a domestic corporation duly incorporated and

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

3. That the plaintif is the registered owner of a parcel of land

4. That sometime on October 2, 2011, defendant asked the plaintif

5. That on January 2012, without the consent of the plaintif,

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

7. That plaintif was forced to litigate and engaged the services of a

8. For the preservation of the rights of the parties pending such

10. Plaintif is willing to post a bond for the issuance of a writ

WHEREFORE, premises considered, it is most respectfully prayed

a) At the outset, plaintif most respectfully seek for the issuance of

b) That, upon plaintif filing a bond in an amount, which this Court

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

d) That the subject property be reconveyed to the plaintif.

Such other relief and remedies as may be deemed just and

Manila, March 18, 2012.

TAN LIBRANDA ONEZA

REPUBLIC OF THE PHILIPPINES )

1. That I am the plaintif in the above-entitled case;

2. That I have caused the preparation of the foregoing complaint

3. The allegations in the said complaint are true and correct of my

4. I hereby certify that I have not commenced any other action or

5. That if I should thereafter learned that a similar action or

6. I executed this verification/certification to attest to the truth of

IN WITNESS WHEREOF, I have hereunto affixed my signature this

SUBSCRIBED AND SWORN to before me, this 18th day of March, in

Doc. No. 11;

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