78 Complaint Annulment of Documents PDF

Republic of the Philippines
REGIONAL TRIAL COURT

First Judicial Region
Branch 4
Baguio City
MAY GRACE A. BONIFACIO,

Plaintiff, Civil Case No. 2341521-64
For: Annulment of Deed of
-versus- Sale, Reconveyance and
Damages
CHAMELYN A. LAWLAW,
Defendant.
x---------------------------------------x
COMPLAINT
Plaintiff by the undersigned counsel, respectfully alleges:
1. That the plaintiff, MAY GRACE A. BONIFACIO, is of legal age,

single, Filipino citizen and a resident of #13 Jacinto Street,
Barangay Governor Pack, Baguio City;
2. That the defendant, CHAMELYN A. LAWLAW, is of legal age,

single, Filipino citizen and a resident of #75 Mahogany street,
Hillside Subdivision, Baguio City where she may be served with
summons and other court processes;
3. That the plaintiff is the lawful owner of a lot with Lot No. 2221,
Psd-05-103024 covered by Original Certificate of Title No. 3782
situated in #30 Loakan, Baguio City consisting of Ten
Thousand (10,000) square meters with an assessed value of
more or less Ten Million Pesos ( P 10,000,000-). Copy of title is
hereto annexed as Exhibit A;
4. That the plaintiff pays the real estate taxes of the said subject
land evidenced by tax declaration. Copy of which is hereto
annexed as Exhibit B;
5. That the plaintiff obtained a loan from defendant in which the

defendant required the title certificate of the above mentioned
lot to be handed to him for safe keeping without executing a
real estate mortgage contract;
1
6. That the above mentioned lot is the subject of the Deed of
Absolute Sale dated December 15, 2007 in favor of the
defendant by virtue of which Transfer Certificate of Title No. T-
21382 dated March 20, 2010 was issued in favor of the
defendant;
7. That the said circumstances in paragraph 6 hereof was made

known to the plaintiff only on June 27, 2017 when he went to
the City Assessor’s Office to pay the real estate tax of the
subject land;
8. That the plaintiff never signed the said Deed of Absolute Sale
and the signature of the plaintiff appearing therein is forged;
9. That by reason of the forged deed of sale and the transfer

certificate of title covering the above mentioned lot, the plaintiff
was compelled to institute this action engaging the services of a
counsel in the amount of P50, 000 as attorney’s fees.
Wherefore, premises considered, it is most respectfully prayed

that judgment be rendered:
1. CANCELLING Transfer Certificate of Title No. T-21382 in the

name of CHAMELYN A. LAWLAW;
2. ANNULLING the Deed of Absolute Sale date January 5, 2016

in favor of CHAMELYN A. LAWLAW;
3. ORDERING the defendant to reconvey the subject lot to plaintiff;
4. ORDERING defendant to pay attorney’s fee in the amount of

P50, 000
Plaintiff further prays for such other reliefs and remedies

deemed just and proper under the premises.
City of Davao, Philippines, 2nd of September, 2019.
2
REPUBLIC OF THE PHILIPPINES }
DONE: IN THE CITY OF BAGUIO } S.S.
X ============================ X
VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
I, MAY GRACE A. BONIFACIO, of legal age, after having been duly

sworn in accordance with law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
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 of
copies of documents and records in my possession;
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.
MAY GRACE A. BONIFACIO

Affiant
SUBSCRIBED AND SWORN to before me this 2nd day of February

2019 at Baguio City. Affiant exhibiting to me her SSS ID No. 6557237
issued on January 10, 2016 at Baguio City.
Doc. No.____;
Page No.____;
Book No.____;
Series of 2019.

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Republic of the Philippines

REGIONAL TRIAL COURT

MAY GRACE A. BONIFACIO,

Plaintiff by the undersigned counsel, respectfully alleges:

1. That the plaintiff, MAY GRACE A. BONIFACIO, is of legal age,

2. That the defendant, CHAMELYN A. LAWLAW, is of legal age,

5. That the plaintiff obtained a loan from defendant in which the

7. That the said circumstances in paragraph 6 hereof was made

9. That by reason of the forged deed of sale and the transfer

Wherefore, premises considered, it is most respectfully prayed

1. CANCELLING Transfer Certificate of Title No. T-21382 in the

2. ANNULLING the Deed of Absolute Sale date January 5, 2016

3. ORDERING the defendant to reconvey the subject lot to plaintiff;

4. ORDERING defendant to pay attorney’s fee in the amount of

Plaintiff further prays for such other reliefs and remedies

City of Davao, Philippines, 2nd of September, 2019.

VERIFICATION AND CERTIFICATION OF NON-FORUM

I, MAY GRACE A. BONIFACIO, of legal age, after having been duly

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

4. I have not commenced any other action or proceeding involving the

5. To the best of my knowledge and belief, no such action or

6. If I should thereafter learn that a similar action or proceeding has

MAY GRACE A. BONIFACIO

SUBSCRIBED AND SWORN to before me this 2nd day of February

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