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Regional Trial Court: Plaintiffs, - Versus

This complaint was filed by spouses Nino and Jackie Presco against Rani Villadolid regarding a property dispute. The Prescos acquired a 500 sqm lot in 2014 according to the deed of sale. In 2019, a survey found that Villadolid's lot had encroached on the Presco's lot by 2.88 meters, overlapping 36 sqm that has existed since 2012. This was due to Villadolid building part of a structure and fence beyond the property line. The Prescos are seeking action to reclaim possession and ownership of the portion of land that is rightfully theirs.

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Hana Danische Elliot
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54 views1 page

Regional Trial Court: Plaintiffs, - Versus

This complaint was filed by spouses Nino and Jackie Presco against Rani Villadolid regarding a property dispute. The Prescos acquired a 500 sqm lot in 2014 according to the deed of sale. In 2019, a survey found that Villadolid's lot had encroached on the Presco's lot by 2.88 meters, overlapping 36 sqm that has existed since 2012. This was due to Villadolid building part of a structure and fence beyond the property line. The Prescos are seeking action to reclaim possession and ownership of the portion of land that is rightfully theirs.

Uploaded by

Hana Danische Elliot
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
MUNTINLUPA CITY

SPOUSES NINO PRESCO and


JACKIE PRESCO,
Plaintiffs,
-versus- CIVIL CASE No. 0123456
For: Accion Reivindicatoria
RANI VILLADOLID,
Defendant.

x---------------------x

COMPLAINT

COMES NOW, Plaintiffs, through the undersigned counsel and unto


this Honorable Court, most respectfully states that:

1. Plaintiffs Nino Presco and Jackie Presco are spouses, both of legal
age Filipino, and currently residing at Lot 12, Block 6, Hukom Street,
Justice Village, Poblacion, Muntinlupa City where they may be served
with summonses, orders, and other court processes;

2. Defendant Rani Villadolid is of legal age, Filipino, and currently


residing at Lot 2, Block 2, Hukom Street, Justice Village, Poblacion,
Muntinlupa City;

3. On 17 June 2014, spouses Presco acquired the 500 sq. m. lot (Lot 1)
through a Deed of Absolute Sale from a certain Ruby Ryza Mae Lee
Kum Kee as shown in ANNEX A;

4. The said parcel of land was covered by TCT No. T-12345 as shown
in ANNEX B. In which has a market value of Php 1, 250, 000.00 and
an assessed value of Php 750, 000.00 as shown in ANNEX C;

5. On 1 July 2019, a relocation survey was conducted by Engr. Princesa


Cacapit over said lot as shown in ANNEX D. The relocation revealed
that Lot 2 has encroached Lot 1 by 2.88 m resulting to an overlap of 36
sq. m. existing since 2012;

6. The said encroachment of Lot 2 is apparent because a portion of the


building and concrete fence was built beyond the property line. Lot 2 which
is covered by TCT No. T-67890 as shown in ANNEX E, is owned and
registered to defendant Rani Villadolid as evidenced by the
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