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    15 Third Party Complaint

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    IanLightPajaro
    1) Pedro Penduko filed a complaint against John Doe for damages caused by the sale of a parcel of land covered by TCT No. T-14344. 2) John Doe had purchased the land in good faith from Anne Curtis and then sold it to Pedro Penduko. 3) The land was later foreclosed because it had been mortgaged by its co-owner Irana. 4) John Doe is now filing a third-party complaint against Anne Curtis, arguing that if he is found liable to Pedro Penduko, then Anne Curtis should be liable to him since she was the original seller.

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    15 Third Party Complaint

    Uploaded by

    IanLightPajaro
    132 views4 pages
    1) Pedro Penduko filed a complaint against John Doe for damages caused by the sale of a parcel of land covered by TCT No. T-14344. 2) John Doe had purchased the land in good faith from Anne Curtis and then sold it to Pedro Penduko. 3) The land was later foreclosed because it had been mortgaged by its co-owner Irana. 4) John Doe is now filing a third-party complaint against Anne Curtis, arguing that if he is found liable to Pedro Penduko, then Anne Curtis should be liable to him since she was the original seller.

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    1) Pedro Penduko filed a complaint against John Doe for damages caused by the sale of a parcel of land covered by TCT No. T-14344. 2) John Doe had purchased the land in good faith from Anne Curtis and then sold it to Pedro Penduko. 3) The land was later foreclosed because it had been mortgaged by its co-owner Irana. 4) John Doe is now filing a third-party complaint against Anne Curtis, arguing that if he is found liable to Pedro Penduko, then Anne Curtis should be liable to him since she was the original seller.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    132 views4 pages

    15 Third Party Complaint

    Uploaded by

    IanLightPajaro
    1) Pedro Penduko filed a complaint against John Doe for damages caused by the sale of a parcel of land covered by TCT No. T-14344. 2) John Doe had purchased the land in good faith from Anne Curtis and then sold it to Pedro Penduko. 3) The land was later foreclosed because it had been mortgaged by its co-owner Irana. 4) John Doe is now filing a third-party complaint against Anne Curtis, arguing that if he is found liable to Pedro Penduko, then Anne Curtis should be liable to him since she was the original seller.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 4

    REPUBLIC OF THE PHILIPPINES

    REGIONAL TRIAL COURT


    11th Judicial Region
    Branch 1, Davao City

    PEDRO PENDUKO, Civil Case No. 9876543-21


    Plaintiff For: COMPLAINT FOR SUM OF
    MONEY AND RECOVERY OF
    -versus- DAMAGES

    JOHN DOE,
    Defendant
    Third Party Plaintiff,.

    -versus-

    ANNE CURTIS,
    Third-Party Defendant.

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

    THIRD PARTY COMPLAINT

    COMES NOW the Third-Party Plaintiff, JOHN DOE, by and through


    his undersigned counsel and pursuant to Rule 6, Sec. 11 of Rules of Court,
    hereby impleads the Third-Party Defendant, ANNE CURTIS and alleges as
    follows:

    1. PEDRO PENDUKO, Plaintiff filed a complaint against JOHN


    DOE, Defendant and Third Party Plaintiff.
    2. PEDRO PENDUKO alleges that the SALE of a parcel of land
    covered by TCT No. T-14344 with JOHN DOE caused damage to
    him.

    3. JOHN DOE, in GOOD FAITH, bought the parcel of land covered


    by TCT No. T-14344 from ANNE CURTIS.

    4. JOHN DOE, in good faith considering that the SALE between JOHN
    DOE and ANNE CURTIS is free from any impediment, sold the
    parcel of land covered by TCT No. T-14344 to PEDRO PENDUKO.

    5. The parcel of land covered by TCT No. T-14344 was foreclosed by


    the Land Bank of the Philippines for the reason that it was mortgaged
    by IRANA, co- owner of the parcel of land covered by TCT No. T-
    14344.

    6. If PEDRO PENDUKO recovers against JOHN DOE any judgment


    for their damages then JOHN DOE is entitled to judgment against
    ANNE CURTIS for all such sums since the SALE of the parcel of
    land covered by TCT No. T-14344 was the sole cause of PEDRO
    PENDUKO’s damages and injuries.

    WHEREFORE, it is respectfully prayed that JOHN DOE, Defendant


    and Third Party Plaintiff, can demand judgment against ANNE CURTIS,
    Third Party Defendant, for all sums that may be adjudged against JOHN
    DOE, as Defendant, in favor of PEDRO PENDUKO, as Plaintiff, together
    with all costs incidental to the defense of the principal suit.

    Davao City, February 12, 2020.

    ADRIAN PAJARO
    Counsel for Petitioner
    Until December 31, 2021
    Attorney’s Roll No. 10772
    PTR No. 7862245 B; 01-02-20;
    Davao City
    IBP O.R. No. 024454; 01-02-20;
    Davao City

    REPUBLIC OF THE PHILIPPINES)


    PROVINCE OF DAVAO DEL SUR) S.S
    IN THE CITY OF DAVAO………..)
    X…………………………………….X

    VERIFICATION AND CERTIFICATION

    I, PEDRO PENDUKO, of legal age, after having been duly sworn in


    accordance with law, depose and state that:
    1. I am a petitioner in the above-stated case representing the republic
    of the Philippines;
    2. I caused the preparation of the foregoing petition;
    3. I have read the contents thereof and the facts stated therein are true
    and correct of my personal knowledge and/or on the basis true and
    authentic records.
    4. I have not commenced any other action or proceeding involving the
    same issues in the Supreme Court, the Court of Appeals, or any other
    tribunal or agency;
    5. To the best of my knowledge and belief, no such action or
    proceeding is pending in the Supreme Court, the Court of Appeals, or
    any other tribunal or agency;
    6. If I should thereafter learn that a similar action or proceeding has
    been filed or is pending before the Supreme Court, the Court of
    Appeals, or any other tribunal or agency, I undertake to report that
    fact within five (5) days therefrom to this Honorable Court.
    IN WITNESS WHEREOF, I have hereunto affixed my signatures this 12 th
    day of February 2019, at Davao City, Philippines.

                                
    PEDRO PENDUKO
    Affiant

    SUBSCRIBED AND SWORN to before me in the City of Davao this


    th
    30 day of April 2016, by PEDRO PENDUKO, who has satisfactorily
    proven her identity to me through his SSS ID issued by the PRC bearing his
    photograph and signature and with VIN 1123-12323232-4, that he is the
    same person who personally signed the foregoing document before me and
    acknowledged that he executed the same.

    WITNESS MY HAND AND SEAL this 12th day of February


    2020 in Davao City, Philippines.

    NOTARY PUBLIC
    Doc. No. 67;
    Page No. 14;
    Book No. 01;
    Series of 2020.

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