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COMPLAINT
The Parties
Metro Manila, has the capacity to sue and be sued and may be
Johny Yamas;
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4. Defendant’s husband was the legal counsel of the plaintiff and of
Development Corporation;
under his name and the same be held in trust for the plaintiff and
under the clear agreement that later on the said land would be
latter to sell the said parcel of land and to receive the proceeds
Attorney dated January 27, 2012 and made an integral part of this
hereof;
the plaintiff and under the agreement they had previously agreed;
9. On February 02, 2012, the said transaction was registered with the
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duplicate copy of title was issued but the same was right away
plaintiff from then on took possession of the said parcel of land and
paid all real estate taxes that were due from the time of acquisition
up to the present;
10. TCT No. T-111-22 was later on subdivided into four parcels of
land covered under TCT Nos. 1234, 5678, 4567, and 6789. TCT
Nos. 1234 and 5678 and was conveyed to the plaintiff but the
Subdivision and covered by OCT No. 1112 was purchased under the
same agreement. Thus, the title was registered to the Atty. Johny
12. The herein defendant who had long been separated from her
husband even before the latter’s death filed a petition for the
petition;
13. Plaintiff being the real owner of the said land which is only held
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the ground that the same is not lost. Attached as Annex “G”
PRAYER
3. Canceling the titles namely TCT No. 91011 in the name of ANGEL
MAY YAMAS to give way to the processing of the Certificates of
Titles in the name of the plaintiff after he has complied with the
requirement of registration in the Registry of Deeds;
Plaintiffs pray for such other relief just and equitable under the
premises.
MARLO LARROSA
Plaintiff
Assisted by:
PAGLINAWAN LAW OFFICE
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Republic of the Philippines)
City of Tagum )s.s.
x - - - - - - - - - - - - - - - - -x
V E R I F I C A T I O N/ C E R T I F I C A T I O N
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I, SANTIAGO CUA, of legal age, Filipino, married and a resident of
Paco, Metro Manila, Philippines, after having been duly sworn to in
accordance with law, hereby depose and say:
That all the facts alleged therein are true and correct on my own
knowledge and belief and authentic records;
SANTIAGO CUA
Affiant
__________________
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