0% found this document useful (0 votes)
21 views26 pages

Fe Complaint

Mari Tesse Ynah Gauan has filed a complaint for forcible entry and damages against defendants Lhena Mang-aagao and Rigorman Loh Loko, who unlawfully occupied her property while she was working abroad. The plaintiff claims that the defendants broke into her property, changed the locks, and have been operating a cafe business without her consent. She seeks restitution of the property, damages, and attorney's fees from the defendants.

Uploaded by

Maureen Olvis
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
0% found this document useful (0 votes)
21 views26 pages

Fe Complaint

Mari Tesse Ynah Gauan has filed a complaint for forcible entry and damages against defendants Lhena Mang-aagao and Rigorman Loh Loko, who unlawfully occupied her property while she was working abroad. The plaintiff claims that the defendants broke into her property, changed the locks, and have been operating a cafe business without her consent. She seeks restitution of the property, damages, and attorney's fees from the defendants.

Uploaded by

Maureen Olvis
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 26

Republic of the Philippines

MUNICIPAL TRIAL COURT


7th Judicial Region
Branch 13
Cebu City

MARI TESSE YNAH GAUAN,


Plaintiff, Civil Case No. ________
For: FORCIBLE ENTRY
AND DAMAGES
-versus-

LHENA MANG-AAGAO,
RIGORMAN LOH LOKO
Defendants,

X--------------------------------------
-/

COMPLAINT

Plaintiff, by counsel, unto this Honorable Court, most respectfully


states THAT:

PREFATORY STATEMENT

1. Forcible Entry under Rule 70 of the Rules of Court, as


amended, provides in SECTION 1. Who may institute
proceedings, and when. - Subject to the provisions of the next
succeeding section, a person deprived of the possession of any
land or building by force, intimidation, threat, strategy, or
stealth, may, at any time within one (1) year after such unlawful
deprivation or withholding of possession, bring an action in the
proper Municipal Trial Court against the person or persons
unlawfully withholding or depriving of possession, or any
person or persons claiming under them, for the restitution of
such possession, together with damages and costs. (1a)

1
JURISDICTION

2. Under Rule 70 of the Rules of Court, as amended, Forcible


Entry as governed by Summary Procedure which provides, all
actions for forcible entry and unlawful detainer, irrespective of
the amount of damages or unpaid rentals sought to be
recovered, shall be governed by the summary procedure
hereunder provided and shall be filed with the Municipal Trial
Court of the city or municipality where the real property or a
portion thereof is situated.

3. Thus, this case falls under the jurisdiction of the Honorable


Municipal Trial Court.

THE PARTIES

4. Plaintiff MARI TESSE YNAH GAUAN (Marites, for


Brevity), of legal age, a Filipino citizen, married and is residing
at 123 Tuscania site, V. Rama, Guadalupe, Cebu City, Cebu
Philippines. For purposes of this case, she may be served with
notices and other processes of this Honorable Court through the
undersigned counsel at BUWAN LAW OFFICES, 8th Floor,
Anthony’s Building, Beverly Hills, Lahug, Cebu City, Cebu
6000 Philippines.

5. Defendants LHENA MANG-AAGAO (Lena, for Brevity) and


RIGORMAN LOH LOKO (Rigor, for Brevity), are both of
legal age, Filipino citizens. Rigor is residing at 123 Tuscania
site, V. Rama, Guadalupe, Cebu City, Cebu Philippines whilst
Lena is residing at 456 Tuscania site, V. Rama, Guadalupe,
Cebu City, Cebu Philippines where they may be served with
Summons and other processes of this Honorable Court.

ALLEGATIONS TO THE CAUSE OF ACTION

6. Plaintiff is the legal and exclusive owner of the property located


at Lot 1457 Beverly Hills Lahug, Cebu City, Cebu 6000
Philippines, which she inherited from her parents in June 19,
2013 Said property is evidenced by Transfer Certificate of Title
412793 (TCT No. 412793) issued in her name. Plaintiff has

2
been in lawful and continuous possession of the property prior
to her temporary departure to the United States for work in
January 2019. A photocopy of the Transfer Certificate of Title
herein attached as Annex “A” and Exhibit “B” and made an
integral part hereof;

7. Due to her work commitments as a nurse abroad, Plaintiff left


the Philippines and is currently residing in New York, NY,
USA, with no intention of relinquishing her exclusive
ownership and possession of the property. Plaintiff has
entrusted the care and upkeep of the property to her sister Maria
Juana to leave it secured and unused during her absence;

8. On or about March 2021 while Plaintiff was in the United


States, Defendants Rigorman Loh Loko and Lhena Mang-aagao
acting without Plaintiff’s knowledge or consent, entered the
subject property. Defendants gained access to the property by
means of breaking and changing locks thus removing security
measures, thereby taking possession of the property. As
evidenced by a photograph herein attached as Exhibit “C” and
made an integral part hereof;

9. Upon unlawfully entering the property, Defendants used the


premises for the construction and operation of a cafe business
under the name of MUNDO Cafe without Plaintiff’s
authorization and it continues to operate despite Plaintiff’s
exclusive right to the property;

10. Plaintiff, upon discovering Defendants' unlawful entry and


occupation of the property on November 6, 2023 through her
sister Maria Juana, immediately made multiple attempts to
message and call her husband Rigor to clarify the issue and
demand to vacate the land in issue, however, defendants refused
to heed such demand and continue to unlawfully occupy and
use the property for their own personal and business gain. An
exchange of messages of the plaintiff and the defendant as a
documented proof of demand is herein attached as Exhibit “D”
and made an integral part hereof;

3
11. At no time did Plaintiff give permission to Defendants to
occupy or use the property for any purpose, much less for the
operation of a business. Defendants have no legal right to
remain on the property, as they are neither co-owners, tenants,
nor possessors of any valid contract or agreement with Plaintiff;

12. Defendants' actions amount to forcible entry of the property,


depriving Plaintiff of her rightful and peaceful possession. The
Defendants’ unauthorized actions have caused Plaintiff to suffer
the loss of use and enjoyment of her exclusive property, to
which she has sole legal entitlement;

13. As a direct result of Defendants' illegal occupation and use of


the property for business purposes, Plaintiff has suffered and
continues to suffer damages by way of emotional distress and
mental anguish due to Defendants' brazen disregard of her
rights;

14. On the 10th day of November 2023, Plaintiff served upon


Defendant, as required by law, a thirty (30) day notice in
writing to vacate the premises, a copy of the demand is herein
attached as Annex “B” and Exhibit “E” and made an integral
part hereof;

15. Here, all the requisites are present;

16. Plaintiff alleged prior physical possession of the property in


question;

17. Plaintiff, herein was deprived of possession by force and


stealth;

18. FORCE. Defendants unlawfully and forcibly detains from


Plaintiff possession of the premises situated at Lot 1457
Beverly Hills Lahug, Cebu City, Cebu Philippines by the
employment of force such that breaking of locks and changing
the same thus removing security measures as a means to enter
the premises;

4
19. STEALTH. Defendants entered said premises on March 2021
unlawfully when the Plaintiff is in the United States;

20. An action is filed within one year from the time the plaintiff,
who is the lawful owner and legal possessor learned of the
deprivation of the physical possession of the property;

21. Under the Property Registration Decree (P.D. No. 1529),


forcible entry can be initiated when a person is deprived of
possession of property;

22. There were attempts to settle the matter at the Barangay Level
but such action failed to arrive at a settlement. A copy of
Certification to File Action is herein attached as Annex “C” and
made an integral part hereof;

23. Judicial Affidavit of plaintiff is attached as Annex “D” and


Exhibit “A” and and made an integral part hereof;

CAUSE OF ACTION

24. Plaintiff repleads by way of reference the allegations in the


foregoing paragraphs.

PRAYER

WHEREFORE, the foregoing premises considered, it is


respectfully prayed of this Honorable Court that, after notice and
hearing, a Judgment be rendered in favor of plaintiff, as follows:

a. Process and Restitution of said premises against Defendants;


b. Reasonable compensation for the use and occupation of the
premises;

c. Ordering defendants solidarily to pay the plaintiff the amount


of ONE HUNDRED THOUSAND (₱100,000.00) PHILIPPINE
CURRENCY as Attorney's Fees; and

5
d. Ordering defendants solidarily to pay the plaintiff the amount
of ONE HUNDRED THOUSAND (₱100,000.00) PHILIPPINE
CURRENCY as Costs of Litigation.

e. Other reliefs just and equitable are likewise prayed for.


MOST RESPECTFULLY SUBMITTED.
27 October 2024.
Cebu City, Cebu Philippines

BUWAN LAW OFFICES


8th Floor, Anthony’s Building, Beverly Hills, Lahug, Cebu City, Cebu.
buwanlaw@gmail.com
Tel. No. 502-3225

Republic of the Philippines….x


City of Cebu…………………...x S.S.

6
VERIFICATION
WITH CERTIFICATION AGAINST FORUM SHOPPING

I, MARI TESSE YNAH GAUAN, of legal age, a Filipino citizen, residing


at 123 Tuscania site, V. Rama, Guadalupe, Cebu City, under oath and state:
1. That I am the plaintiff in the above entitled case and have caused the
preparation of the said complaint and I am authorized to sign this
Verification;
2. That I have read the pleading and the allegations in the pleading are
true and correct based on my personal knowledge and based on
authentic documents;
3. That the pleading is not filed to harass, cause unnecessary delay, or
needlessly increase the cost of litigation;
4. That the factual allegations therein have evidentiary support after
reasonable opportunity for discovery;
5. That I have not therefore commenced any action or filed any claim
involving the same issues in any court, tribunal or quasi-judicial
agency;
6. That to the best of my knowledge, no such other action or claim is
pending therein; and
7. That if I should thereafter learn that the same or similar action or
claim has been filed or is pending, I shall report that fact within five
(5) calendar days therefrom to this Court.
IN WITNESS WHEREOF, I set my hand this 27th day of October
2024, in Cebu City, Cebu, 6000 Philippines.

MARIE TESS YNAH GAUAN


Affiant

SUBSCRIBED AND SWORN to before me this 27th day of November


2024 at Cebu City, Cebu, 6000 Philippines, the affiant exhibiting to me her
Driver’s License with No. 1111111 valid until 2026/04/13 as competent
proof of identity.

7
Doc No. ______
Page No. ______
Book No. ______
Series of 2024.

ATTY. MAUREEN M. OLVIS


Roll of Attorney No. 18855
PTR No. 8815187, Cebu City
IBP No. 581888
MCLE Compliance No. IX-000858,
November 10, 2023

8
ANNEX “A”

9
ANNEX “B”

10
ANNEX “C”

11
ANNEX “D”

12
Republic of the Philippines
MUNICIPAL TRIAL COURT
7th Judicial Region
Branch 13
Cebu City

MARI TESSE YNAH GAUAN,


Plaintiff, Civil Case No. ________
For: FORCIBLE ENTRY
AND DAMAGES
-versus-

LHENA MANG-AAGAO,
RIGORMAN LOH LOKO
Defendants,

X--------------------------------------
-/

Republic of the Philippines )


Cebu City ………………. )S.S.

JUDICIAL AFFIDAVIT of
MARI TESSE YNAH GAUAN

I, MARI TESSE YNAH GAUAN, of legal age, a Filipino citizen, and


a resident of 123 Tuscania site, V. Rama, Guadalupe, Cebu City, after
having been duly sworn to in accordance with the law, do hereby depose and
state THAT:

PRELIMINARY STATEMENT

The person examining me is Atty. Maureen M. Olvis, with office


address at 8th Floor, Anthony’s Building, Beverly Hills, Lahug, Cebu City,
Cebu, 6000 Philippines. The examination is being held at the same address. I
am answering her questions, fully conscious that I do so under oath and may
face criminal liability for false testimony or perjury.

This affidavit/testimony of petitioner Mari Tesse Ynah Gauan is being


initiated to prove that the defendants Lhena Mang-aagao and Rigorman Loh
Loko forcibly entered the plaintiff’s property and continues to possess and

13
use the same without authorization or consent. The petitioner’s testimony is
also provided to prove that the defendants Lhena Mang-aagao and Rigorman
Loh Loko refused to vacate the subject property upon and after demand of
the plaintiff.

Q1: What brought you here today?


A1: I am here today to file a case against Lhena Mang-aagao and
Rigorman Loh Loko who unlawfully and forcibly entered and
occupied my property without my authorization or consent.

Q2: Who are Lhena Mang-aagao and Rigorman Loh Loko as you just
mentioned?
A2: Lhena Mang-aagao is my husband Rigorman Loh Loko’s
Mistress.

Q3: What is your relationship to the property in question?


A3: I am the sole owner of the property located at Lot 1457 Beverly
Hills Lahug, Cebu City, Cebu Philippines which I inherited from my
parents in June 2013 as evidenced by Transfer Certificate of Title
412793 (TCT No. 412793).

Q4: I am marking the copies of the documentary evidence of


Certificate Transfer of Title as EXHIBIT “B”. Please go over the
document and tell me if this is the same certificate which you handed
to me earlier (Handing to the witness photocopy of the TCT marked
as EXHIBIT “B”).
A4: (Looking at the document marked as EXHIBIT “B”). Yes, this is
the same document.

Q5: Why are you currently abroad?


A5: I am currently abroad for my work as a nurse in New York.

Q6: When did you first become aware of the forcible entry?
A6: I was informed of the forcible entry on November 6, 2023 when
my sister Maria Juana told me about it and caused me to return to the
Philippines and visit my family including my property.

Q7: Who entered your property without permission?


A7: My husband, Rigorman Loh Loko and his mistress, Lhena
Mang-aagao, forcibly and unlawfully entered my property without my
authorization or consent.

Q8: How did you know Lhena Mang-aagao?


A8: I came to know Lhena Mang-aagao just when I came home to the
Philippines and visited my property. It was during my visit that I met
her.

14
Q9: What activities have they engaged in on your property?
A9: They have been using my property for the operation of their cafe
business under the name of MUNDO Cafe, which I did not authorize.
(handing to the examining lawyer the documentary proofs).

Q10: I am marking the copies of the documentation of the


photographs as EXHIBIT “B”. Please go over the images and tell me
if these are the same images which you handed to me earlier
(Handing
to the witness photographs marked as EXHIBIT “C”).
A10: (Looking at the images marked as EXHIBIT “C”). Yes, these
are
the same photographs.

Q11: Did you give them permission to use your property?


A11: No, I never gave my husband, Rigor, permission to enter or use
my property at any time.

Q12: Did you attempt to contact your husband regarding the


unlawful occupation on your property?
A12: Yes, I and my sister Maria Juana, we made several attempts to
reach out to the defendants to vacate my property. In fact, on
November 10, 2023, I, through my lawyer, sent a formal demand
letter to the defendants, giving them a 30-day notice demanding them
to vacate the aforementioned premises. The letter was duly received,
but the defendants did not respond to the demand. (handing to the
examining lawyer the documents).

Q13: I am marking the copies of the documentation of the demand via


messages as EXHIBIT “C” and the demand letter as EXHIBIT “D”.
Please go over the documents and tell me if these are the same
documents which you handed to me earlier (Handing to the witness
documents marked as EXHIBITS “D” and “E”).
A13: (Looking at the documents marked as EXHIBITS “D” and “E”).
Yes, these are the same documents.

Q14: How has this situation affected you?


A14: Their unauthorized actions have caused me significant
emotional distress impacting my ability to manage my property.

Q15: What legal action are you seeking?


A15: I am seeking to regain possession of my property and request a
restraining order against Rigorman Loh Loko and Lhena Mang-aagao
to prevent future unauthorized entry.

Q16: Is there anything further you wish to state or address before you
conclude this judicial affidavit?
A16: In spite of my considerable patience and persistent efforts to

15
establish contact with the defendants, it appeared that my endeavors
were ultimately unproductive, and they exhibited a lack of
responsiveness. The extended delay unlawful occupation in my
property resulted in missed opportunities for potential use.
Regrettably, I found myself with no recourse but to seek legal redress
by going to court. The manner in which Rigorman Loh Loko and
Lhena Mang-aagao gave rise to considerable distress on my part.

Q17: In filing this Petition, what is therefore your prayer to the


Honorable Court?
A17: It is most respectfully prayed that, after due notice and hearing,
the Honorable Court would order Defendants as follows:

a. to vacate the premises and give back the rightful possession to


me as the legal owner and rightful possessor of the same.
b. Reasonable compensation for the use and occupation of the
premises;
c. Ordering defendants solidarily to pay the plaintiff the amount of
ONE HUNDRED THOUSAND (₱100,000.00) PHILIPPINE
CURRENCY as Attorney's Fees; and
d. Ordering defendants solidarily to pay the plaintiff the amount of
ONE HUNDRED THOUSAND (₱100,000.00) PHILIPPINE
CURRENCY as Costs of Litigation.
e. I likewise pray for other reliefs that are just and equitable under
the circumstances.

The affiant/witness herein warrants that the copy of the Exhibits


attached to this Judicial Affidavit are faithful copies of the original.

Q18: Do you confirm and affirm that in answering all the above, you
are fully aware that you are under oath, and that you may be criminally
liable for false testimony or perjury?
A18: Yes, I do.

---------------------------------END OF INQUIRY----------------------------------

16
AFFIANT’S OATH AND ATTESTATION

I, MARI TESSE YNAH GAUAN, of legal age, a Filipino citizen,


residing at 123 Tuscania site, V. Rama, Guadalupe, Cebu City, of legal
capacity and competence to comprehend without any vice of consent hereby
attests to have voluntarily and truthfully made the answers to the foregoing
questions.

IN WITNESS WHEREOF, have hereunto set my hand this 27 th day of


October 2024, Cebu City, Cebu, 6000 Philippines.

MARI TESSE YNAH GAUAN


Affiant

SUBSCRIBED AND SWORN TO before me this 27th day of


October 2024, Cebu City, Cebu, 6000, Philippines, affiant exhibited to me
her Driver’s License No. 1111111 as competent proof of identity.

Doc. No. ; ____________


Page No. ; ____________
Book No. ; ____________
Series of 2024

ATTY. MAUREEN M. OLVIS


Roll of Attorney No. 18855
PTR No. 8815187, Cebu City
IBP No. 581888
MCLE Compliance No. IX-000858,
November 10, 2023

LAWYER’S SWORN ATTESTATION

17
I, Atty. Maureen M. Olvis, of legal age, Filipino, with office address at 8 th
Floor, Anthony’s Building, Beverly Hills, Lahug, Cebu City, Cebu, after
having been duly sworn to in accordance with law hereby depose and say
that:
1. I am the counsel who conducted and supervised the examination of
Mari Tess Ynah Gauan for the purpose of preparing her Judicial
Affidavit which will be submitted as her direct testimony in Court;
2. I faithfully recorded the foregoing questions I asked from the witness
and her corresponding answers;
3. Neither I nor any other person coached the said witness regarding her
answers; and
4. I am aware that a false attestation shall subject me to disciplinary
actions, including disbarment.

IN WITNESS WHEREOF, I have hereunto affixed my signature this


October 27, 2024 at Cebu City, Cebu, Philippines.

ATTY. MAUREEN M. OLVIS


Roll of Attorney No. 18855
PTR No. 8815187, Cebu City
IBP No. 581888
MCLE Compliance No. IX-000858,
November 10, 2023

SUBSCRIBED AND SWORN to before me this October 27, 2024 at Cebu


City, Cebu Philippines, affiant exhibiting his IBP ID with Roll of Attorney
No. 18855, bearing her photograph and signature.

Doc. No. ; ____________


Page No. ; ____________
Book No. ; ____________
Series of 2024

ATTY.
MARCO MENDEZ
Notary Public
Roll of Attorney No. 14002
PTR No. 1234581, February 17, 2018, Cebu City
IBP No. 656164
MCLE Compliance No. XX-889916381,
December 1, 2018

EXHIBIT “A”

18
JUDICIAL AFFIDAVIT of
MARI TESSE YNAH GAUAN

I, MARI TESSE YNAH GAUAN, of legal age, a Filipino citizen, and


a resident of 123 Tuscania site, V. Rama, Guadalupe, Cebu City, after
having been duly sworn to in accordance with the law, do hereby depose and
state THAT:

PRELIMINARY STATEMENT

The person examining me is Atty. Maureen M. Olvis, with office


address at 8th Floor, Anthony’s Building, Beverly Hills, Lahug, Cebu City,
Cebu, 6000 Philippines. The examination is being held at the same address. I
am answering her questions, fully conscious that I do so under oath and may
face criminal liability for false testimony or perjury.

This affidavit/testimony of petitioner Mari Tesse Ynah Gauan is being


initiated to prove that the defendants Lhena Mang-aagao and Rigorman Loh
Loko forcibly entered the plaintiff’s property and continues to possess and
use the same without authorization or consent. The petitioner’s testimony is
also provided to prove that the defendants Lhena Mang-aagao and Rigorman
Loh Loko refused to vacate the subject property upon and after demand of
the plaintiff.

Q1: What brought you here today?


A1: I am here today to file a case against Lhena Mang-aagao and
Rigorman Loh Loko who unlawfully and forcibly entered and
occupied my property without my authorization or consent.

Q2: Who are Lhena Mang-aagao and Rigorman Loh Loko as you just
mentioned?
A2: Lhena Mang-aagao is my husband Rigorman Loh Loko’s
Mistress.

Q3: What is your relationship to the property in question?


A3: I am the sole owner of the property located at Lot 1457 Beverly
Hills Lahug, Cebu City, Cebu Philippines which I inherited from my
parents in June 2013 as evidenced by Transfer Certificate of Title
412793 (TCT No. 412793).

Q4: I am marking the copies of the documentary evidence of


Certificate Transfer of Title as EXHIBIT “B”. Please go over the
document and tell me if this is the same certificate which you handed
to me earlier (Handing to the witness photocopy of the TCT marked
as EXHIBIT “B”).
A4: (Looking at the document marked as EXHIBIT “B”). Yes, this is
the same document.

19
Q5: Why are you currently abroad?
A5: I am currently abroad for my work as a nurse in New York.

Q6: When did you first become aware of the forcible entry?
A6: I was informed of the forcible entry on November 6, 2023 when
my sister Maria Juana told me about it and caused me to return to the
Philippines and visit my family including my property.

Q7: Who entered your property without permission?


A7: My husband, Rigorman Loh Loko and his mistress, Lhena
Mang-aagao, forcibly and unlawfully entered my property without my
authorization or consent.

Q8: How did you know Lhena Mang-aagao?


A8: I came to know Lhena Mang-aagao just when I came home to the
Philippines and visited my property. It was during my visit that I met
her.

Q9: What activities have they engaged in on your property?


A9: They have been using my property for the operation of their cafe
business under the name of MUNDO Cafe, which I did not authorize.
(handing to the examining lawyer the documentary proofs).

Q10: I am marking the copies of the documentation of the


photographs as EXHIBIT “B”. Please go over the images and tell me
if these are the same images which you handed to me earlier
(Handing
to the witness photographs marked as EXHIBIT “C”).
A10: (Looking at the images marked as EXHIBIT “C”). Yes, these
are
the same photographs.

Q11: Did you give them permission to use your property?


A11: No, I never gave my husband, Rigor, permission to enter or use
my property at any time.

Q12: Did you attempt to contact your husband regarding the


unlawful occupation on your property?
A12: Yes, I and my sister Maria Juana, we made several attempts to
reach out to the defendants to vacate my property. In fact, on
November 10, 2023, I, through my lawyer, sent a formal demand
letter to the defendants, giving them a 30-day notice demanding them
to vacate the aforementioned premises. The letter was duly received,
but the defendants did not respond to the demand. (handing to the
examining lawyer the documents).

Q13: I am marking the copies of the documentation of the demand via

20
messages as EXHIBIT “C” and the demand letter as EXHIBIT “D”.
Please go over the documents and tell me if these are the same
documents which you handed to me earlier (Handing to the witness
documents marked as EXHIBITS “D” and “E”).
A13: (Looking at the documents marked as EXHIBITS “D” and “E”).
Yes, these are the same documents.

Q14: How has this situation affected you?


A14: Their unauthorized actions have caused me significant
emotional distress impacting my ability to manage my property.

Q15: What legal action are you seeking?


A15: I am seeking to regain possession of my property and request a
restraining order against Rigorman Loh Loko and Lhena Mang-aagao
to prevent future unauthorized entry.

Q16: Is there anything further you wish to state or address before you
conclude this judicial affidavit?
A16: In spite of my considerable patience and persistent efforts to
establish contact with the defendants, it appeared that my endeavors
were ultimately unproductive, and they exhibited a lack of
responsiveness. The extended delay unlawful occupation in my
property resulted in missed opportunities for potential use.
Regrettably, I found myself with no recourse but to seek legal redress
by going to court. The manner in which Rigorman Loh Loko and
Lhena Mang-aagao gave rise to considerable distress on my part.

Q17: In filing this Petition, what is therefore your prayer to the


Honorable Court?
A17: It is most respectfully prayed that, after due notice and hearing,
the Honorable Court would order Defendants as follows:

f. to vacate the premises and give back the rightful possession to


me as the legal owner and rightful possessor of the same.
g. Reasonable compensation for the use and occupation of the
premises;
h. Ordering defendants solidarily to pay the plaintiff the amount of
ONE HUNDRED THOUSAND (₱100,000.00) PHILIPPINE
CURRENCY as Attorney's Fees; and
i. Ordering defendants solidarily to pay the plaintiff the amount of
ONE HUNDRED THOUSAND (₱100,000.00) PHILIPPINE
CURRENCY as Costs of Litigation.
j. I likewise pray for other reliefs that are just and equitable under
the circumstances.

The affiant/witness herein warrants that the copy of the Exhibits


attached to this Judicial Affidavit are faithful copies of the original.

21
Q18: Do you confirm and affirm that in answering all the above, you
are fully aware that you are under oath, and that you may be criminally
liable for false testimony or perjury?
A18: Yes, I do.

---------------------------------END OF INQUIRY----------------------------------

22
EXHIBIT “B”

23
EXHIBIT “C”

24
EXHIBIT “D”

25
EXHIBIT “E”

26

You might also like