Metropolitan Trial Court in Cities

REPUBLIC OF THE PHILIPPINES
METROPOLITAN TRIAL COURT IN CITIES

City of Manila
Branch 30
REINA CLARISE TOKITA

Plaintiff,
- versus - Civil Case No. 12954
FOR: RECOVERY OF ACTUAL

DAMAGES AND ATTORNEY’S FEES
KATE ZABALA
Defendant.
x-----------------------------------------------------x
COMPLAINT
COMES NOW, the plaintiff, REINA CLARISE TOKITA, through the undersigned counsel
and unto this Honorable Court, most respectfully avers:
1. That the plaintiff, REINA CLARISE TOKITA, is of legal age, Filipino citizen, single,
and a resident of 41 C Panghulo, Obando, Bulacan;
2. That the defendant, KATE ZABALA, is of legal age, Filipino citizen, single, and a
resident of Blk 3 Lot 16 Rosalia 2 Subdivision, Habay II, Bacoor City, Cavite;
3. That the defendant is the descendant of one Mr. Alfredo Zabala, who left an estate to
defendant;
4. That the plaintiff was the counsel of therein defendant for the settlement of the estate of
the deceased involving seven (7) parcels of land situated in Tagaytay City, Philippines;
5. That on October 2, 2017, the project of partition submitted by Attorney Tokita was
approved and the said lands were adjudicated to Kate Zabala;
6. That on November 12, 2017, plaintiff and defendant executed a contract stating that the
attorney’s fees of Attorney Tokita were to be secured under the said land;
7. That after the said adjudication, the attorney’s fees charged to Attorney Tokita was
P50,000;
8. That on December 20, 2017, the estate was declared closed and terminated resulting to
non-payment of the Attorney’s fees of Attorney Tokita.
WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable

Court that judgment be rendered ordering the defendant:
1. To pay plaintiff the damages for breach of contract;

2. To pay plaintiff the Attorney’s fees; and
3. To pay the plaintiff the cost of the suit.
Plaintiff likewise prays for such other reliefs that are deemed just and equitable under the
premises.
Atty. Chrysill Ariza M. Valencia
Counsel for Plaintiff
PTR No. 9856425, Tagaytay City, 1/2/17
IBP OR No.786456, Tagaytay City, 1/2/17
Attorney’s Roll No. 89749
MCLE Compliance Certificate No. IV-0087615,
Pasig City, 1/2/17
VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING
I, REINA CLARISE TOKITA, of legal age, Filipino, after having been sworn, in accordance
with law, hereby depose and state that:
1. I am the Plaintiff in the above-captioned case;
2. I have read and understood the contents hereof of this Petition for Review, and the facts
herein alleged are true and correct of my own knowledge and based on available verifiable
records;
3. I heretofore have not commenced any other action or proceeding or any claim, or filed any
claim involving the same issues raised in the above-captioned case, in this Honorable
Supreme Court, in the Court of Appeals, nor the different Divisions thereof, nor in any other
court or tribunal or agency and, to the best of my knowledge, no such other action or claim
is pending therein;
4. I hereby undertake to notify this Honorable Court of such fact within five (5) days from
receipt of such knowledge, should I come to learn that the same or a similar action or claim
has been filed or pending in the Supreme Court, Court of Appeals, the different Divisions
thereof, or any other court or tribunal or agency;
5. I am executing this sworn statement in compliance with Section 5, Rule 7 of the 1997 Rules
of Court.
REINA CLARISE TOKITA

Affiant
SUBSCRIBED and SWORN TO before me this 21st day of April 2017 at Manila
City, Philippines, affiant exhibiting to me her SSS ID with ID No. 9867282739 issued by
the Social Security System, as competent evidence of her identity, and she personally
acknowledged to me that the foregoing “Petition” is her free and voluntary act and deed.
Machine copy of this SSS ID is hereto attached.
Atty. Sophia Clarisse Paglinawan

Notary Public
PTR No. 2463667, Valenzuela City, 1/2/17
IBP OR No. 654521, Valenzuela City, 1/2/17
Attorney’s Roll No. 89725
MCLE Compliance Certificate No. IV-0987315,
Pasig City, 1/2/17
Doc No. _____;

Page No. _____;
Book No. _____;
Series of 20______.

Metropolitan Trial Court in Cities

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REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT IN CITIES

REINA CLARISE TOKITA

- versus - Civil Case No. 12954

FOR: RECOVERY OF ACTUAL

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable

1. To pay plaintiff the damages for breach of contract;

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

1. I am the Plaintiff in the above-captioned case;

REINA CLARISE TOKITA

Atty. Sophia Clarisse Paglinawan

Doc No. _____;

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