Complaint Villamar
Complaint Villamar
Complaint Villamar
MAGDALENA BUSTILLOS,
Plaintiff, Civil Case No. ______
______________________,
Defendant.
x-----------------------x
COMPLAINT
2. Plaintiff is the forced and legal heir of Ricarda Bustillos who died
single and who is the lawful owner of a certain parcel of land with an
assessed value of Php2,560.00 located at Brgy. Pinipin, Sta. Cruz, Ilocos
Sur, under Katibayan ng Orihinal na Titulo Blg. P-39532 and more
particularly described as follows:
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Bounded on the E., along line 1-2 by Bayugao River (8-
70:00 meters wide);on the S., along line 2-3 by Lot No. 5567,
Cad-546-D; on the W., along line 3-4 by South China Sea; on
the N., along line 4-5 by Lot No. 5563, cad-546-D;
Bearings Grid.
Note:
8. To deter others who maybe similarly situated and for the good of
the public defendant shall likewise be adjudge liable for examplary
damages in the amount of not less than Php50,000.00;
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9. To protect her rights and interest plaintiff was constrained to
engage the services of counsel for an agreed amount of Php25,000.00 as
attorney’s fee and Php1,500.00 for every appearance of counsel.
PRAYER
Other reliefs just and equitable under the above premises are
likewise prayed for.
WILFREDO R. CORTEZ
Counsel for the Plaintiff
Sta. Cruz, Ilocos Sur
IBP No. 28105/1-17-18
PTR No. 8890557/1-4-18
Roll No. 33768
MCLE Compliance V-0013871
Issued at Pasig City
on February 11, 2016
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That I am the Plaintiff in the above entitled case;
That all the allegations stated therein are true and correct and
based on genuine or authentic records;
FLORA L. VILLAMAR
affiant
Valid ID NO.
WILFREDO R. CORTEZ
Notary Public
Until December 31, 2018
Sta. Cruz, Ilocos Sur
PTR NO. 8890557/1-4-18
IBP NO. 28105/1-4-18
ROLL NO. 33768
TIN NO. 170-449-903
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