7 Judicial Region Branch 87, Mandaue City, Cebu
7 Judicial Region Branch 87, Mandaue City, Cebu
7 Judicial Region Branch 87, Mandaue City, Cebu
-versus-
AMENDED C O M P L A I N T
7. The subject lot is previously known as Lot No. 4676 declared under the
ownership of the late Sps. Tereso Saso and Cecilia Saso with an area of
353 square meters. Eventually, the subject lot was under the co-
ownership of plaintiff’s parents and the defendants SPS. JESUS SASO
and AIDA CALIFLORES SASO. The following are the Tax Declarations
of the subject lot which were then declared under the ownership of Sps.
Tereso Saso and Cecilia Saso and then under the co-ownership with the
defendants;
11.Plaintiff had already erected his house on the 49 square meter lot that she
acquired from his father which is located on a portion of Lot 4676-A
declared under Tax Declaration No. 21752 in the name of the defendants;
12.Plaintiff was caught unaware that her name was not included in the Tax
Declaration of Lot 4676-A as to her ownership of 49 square meters. She
confronted the defendants about it but she was ignored by his brother;
13.In order to protect plaintiff’s interest on the subject lot, she executed an
Affidavit of Adverse Claim and cause the annotation of the same at the
Office of the Provincial Assessor of the Cebu Province. She likewise
executed a Renewal of her Adverse Claim on the subject lot. A copy of
the Adverse Claim and a copy of the renewal of the adverse claim are
hereby attached as Annexes “L” and “M” respectively;
15. Plaintiff had found out that defendants SPS. JESUS SASO and AIDA
CALIFLORES SASO had executed a Deed of Sale on a portion of Lot
4676-A of about 130 square meters to SPS. RAMSES Y. PEPITO and
MARIA AMPARO G. PEPITO and the certificate of title of the lot as
well as the tax declaration was eventually transferred in their name. A
copy of the Deed of Sale is hereby attached as Annex “O”;
16. That Lot 4676-A was subdivided into two parcel, one in the name of
SPS. RAMSES Y. PEPITO and MARIA AMPARO G. PEPITO Transfer
Certificate of Title No. 111-2018005597 and Tax Declaration No. 82514
to the extent of 130 square meters and the other which is 30 square
meters in the name of SPS. JESUS SASO and AIDA CALIFLORES
SASO;
18.In order to protect the interest of the plaintiff, she was constrained to
retain the services of the undersigned counsel to whom he agreed to pay
the sum of P20,000 as attorney’s fee.
PRAYER
Other reliefs that are just and equitable under the premises are likewise
prayed for.
Respectfully submitted.
April 30, 2021