Municipal Trial Court: Plaintiff

Republic of the Philippines
MUNICIPAL TRIAL COURT

Second Judicial Region
Alicia, Isabela
MARK ANTONY B. BUQUEL,

Plaintiff,
Civil Case No. _____________
versus For: Forcible Entry
ROLANDO B. JULIAN,
Defendant,
x-------------------------------------------x
COMPLAINT
Plaintff, thru counsel, to the Honorable Court, most respectfully states that:
THE PARTIES
1. Plaintiff, MARK ANTONY B. BUQUEL, is of legal age, Filipino citizen

and a resident of Bliss Core, Brgy. Paddad, Alicia, Isabela, where they can
be served with judicial processes;
2. Defendant, ROLANDO B. JULIAN, is of legal age, Filipino citizen and a

resident of Brgy. Paddad, Alicia, Isabela;
FACTUAL ANTECEDENTS
ESTABLISHING CAUSES OF ACTION
3. Plaintiff is the true and registered owner of a parcel of land situated in Purok
7, Paddad, Alicia, Isabela, consisting of Two Thousand (2,000) square
meters, more or less, and identified as Lot 2222 and covered by Transfer
Certificate of Title No. 22222 of the Registry of Deeds of Isabela, a copy of
the said Transfer Certificate of Title is herein attached as Annex “A”;
4. The plaintiffs bought the subject real property in 2019 through a Deed of
Absolute Sale from HAYDEE DANCEL, a copy of the Deed of Absolute
Sale is hereto attached as Annex “B”
5. After the entry in the Registry, plaintiff immediately took possession of the
subject real property by erecting a perimeter fence throughout the subject
real property, photograph of the structure put up by the plaintiff are hereto
attached as Annex “C”
6. On November 24, 2020, while the plaintiff was staying at the residence of
his mother in Ramon, Isabela, the defendant without the knowledge, consent
and authority of the plaintiff, by force, stealth and strategy entered the land
described in paragraph 3, encroached and took a portion of the land having
an area of Five Hundred (500) square meters with the following boundaries:
on the Northeast the remaining portion; on the Southeast by the provincial
road;
7. Simultaneous to their unlawful entry, defendant started construction of a

Nipa Hut notwithstanding repeated demands for them to stop and to desist
from further acts of dispossession;
8. Plaintiff, by themselves and through their representative, repeatedly

demanded of the defendant to vacate the area occupied by them and to
deliver the peaceful possession of the same to them, but defendants, without
any just or legal reason, refused and continue to refuse to leave the premises
and restore peaceful possession to the plaintiffs of the portion which they
unlawfully wrested from the plaintiff;
9. Efforts for a possible settlement and/or reconciliation was exerted by the

plaintiff by seeking the intervention of the Lupon Tagapamayapa of
Barangay Paddad, Alicia, Isabela, regrettably all efforts to amicably settle
their dispute was in vain, a copy of the Certification to File Action issued by
the Lupon Secretary is hereto attached as Annex “D”
10.That plaintiff was forced to resort to judicial action and spent the amount
of TWENTY THOUSAND (P20,000.00) PESOS as attorney’s fees,
and Two Thousand (P2,000.00) per hearing as appearance fee, filing
fee and other incidental expenses;
11.That this action is being filed within a period of one (1) year from the
date of the unlawful deprivation of the subject real property.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court, that after due notice and hearing, judgement be rendered in favor
of the Plaintiff ordering the herein Defendants and all persons claiming rights
under him to:
1. Permanently vacate the subject real property and give the immediate right
of possession to the Plaintiff;
2. Ordering the defendants to cease and desist from further disturbing and
molesting the proprietary rights and interest of the plaintiffs over the
house and lot in question
3. Pay plaintiff the amount of Twenty Thousand Pesos (P20,000.00) by way

of attorney’s fees, and Two Thousand (P2,000.00) per hearing as
appearance fee, filing fee and other incidental expenses of litigation;
Other reliefs just and equitable under the circumstances are likewise prayed
for.
Alicia, Isabela. October 5, 2021.
ATTY. JUSTIN GABRIEL R. LLANA

Counsel for Plaintiff
Roll No. 111111
PTR No. 112491 01/06/2021 Ilagan City
IBP No. 911124 01/04/2021 Ilagan City
MCLE Compliance XII-0321052-04/15/21
Tel. No. (078) 324-6685
Cell Phone No. 0975 207 9905
E-mail Address: jtin1124@gmail.com
Block 4 Lot 3 La Fortuna Village
Paddad, Alicia, Isabela
REPUBLIC OF THE PHILIPPINES )
MUNICIPALITY OF ALICIA )SS.
PROVINCE OF ISABELA )
VERIFICATION AND CERTIFICATION

AGAINST FORUM-SHOPPING
I, MARK ANTONY B. BUQUEL, of legal age and a resident of Brgy.

Paddad, Alicia, Isabela after having been duly sworn to in accordance with law, do
hereby depose and state that:
1. I am the petitioner in the foregoing Complaint and I have caused the

preparation of the same, that contents of which are all true and correct to
the best of my knowledge, information and belief;
2. The Complaint is not filed to harass, cause unnecessary delay, or

needlessly increase the cost of litigation;
3. The factual allegations therein have evidentiary support or, if specifically

so identified, will likewise have evidentiary support after a reasonable
opportunity for discovery;
4. I certify that neither have I commenced nor is there any pending Petition
of similar nature before any court, tribunal or quasi-judicial agency, and
if I should hereafter learn that the same or similar Petition has been filed
or is pending in any court, tribunal of quasi-judicial agency, I shall report
the fact within five (5) days therefrom to this Honorable Court.
IN WITNESS WHEREOF, I have hereunto set my hand this 5 th day of

October, 2021 in Alicia, Isabela.
MARK ANTONY B. BUQUEL

Affiant
SUBSCRIBED AND SWORN to before this 5th day of October, 2021 at

Alicia, Isabela, Philippines. Affiant exhibited to me her respective proof of
identity, to wit:
NAME ID TYPE ID NO. EXPIRATION DATE

MARK ANTONY B. BUQUEL PRC ID 123456 September 1, 2023
This petition consists of five (5) pages including the page where this notarial
act is written.
ATTY. JUGA AICILA

NOTARY PUBLIC
Paddad, Alicia, Isabela
Roll No. 123456
PTR No. 123456 01/10/2021 Ilagan City
IBP No. 123456 01/05/2020 Ilagan City
MCLE Compliance XII-111111-02/29/21
Doc. No.: 29;

Page No. : 25;
Book No. II;
Series of 2021

Municipal Trial Court: Plaintiff

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Republic of the Philippines

MUNICIPAL TRIAL COURT

MARK ANTONY B. BUQUEL,

1. Plaintiff, MARK ANTONY B. BUQUEL, is of legal age, Filipino citizen

2. Defendant, ROLANDO B. JULIAN, is of legal age, Filipino citizen and a

7. Simultaneous to their unlawful entry, defendant started construction of a

8. Plaintiff, by themselves and through their representative, repeatedly

9. Efforts for a possible settlement and/or reconciliation was exerted by the

WHEREFORE, premises considered, it is most respectfully prayed of this

3. Pay plaintiff the amount of Twenty Thousand Pesos (P20,000.00) by way

Alicia, Isabela. October 5, 2021.

ATTY. JUSTIN GABRIEL R. LLANA

VERIFICATION AND CERTIFICATION

I, MARK ANTONY B. BUQUEL, of legal age and a resident of Brgy.

1. I am the petitioner in the foregoing Complaint and I have caused the

2. The Complaint is not filed to harass, cause unnecessary delay, or

3. The factual allegations therein have evidentiary support or, if specifically

IN WITNESS WHEREOF, I have hereunto set my hand this 5 th day of

MARK ANTONY B. BUQUEL

SUBSCRIBED AND SWORN to before this 5th day of October, 2021 at

NAME ID TYPE ID NO. EXPIRATION DATE

ATTY. JUGA AICILA

Doc. No.: 29;

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