Ejectment Forcible Entry Property

7/30/2019 Ejectment Forcible Entry Property

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JUDICIAL FORMS (SUMMARY PROCEEDINGS)

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E J E C T M E N T ( F O R C I B L E E N T R Y )COMPLAINT

Republic of the PhilippinesNATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURTQUEZON CITYBranch 031

JUAN AYSION SANTOSPlaintiff,

-versus- CIVIL CASE No.

Q-12345For: EJECTMENT (FORCIBLE ENTRY)

JOHN CHIU CO Defendant.x - - - - - - - - - - - - - - - - - - - - - - - - - - -x

C O M P L A I N T

PLAINTIFF, through the undersigned counsel, and unto this HonorableCourt most respectfully submits this Complaint for Forcible Entry and in supporthereof makes the following assertions:

1. Plaintiff JUAN AYSION SANTOS, is residing at #123 Narra St.,Fairville, Quezon City, where he may be served with court order and otherprocesses;

2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville,Quezon City where he may be served with summons, order and other courtprocesses;

3. Plaintiff became owner of a certain parcel of land, through a Deed of Salefrom the original owner, JANICE DY LEE. (A copy of the Deed of Saleis hereto attached asAnnex A);

4. The parcel of land, situated in #129 Fairville, Barangay Pangsy, QuezonCity, is covered by Transfer of Certificate of Title No. 12345 issued by theRegister of Deeds od Quezon City and is more particularly described, asfollows:

(Description)

(Copy of TCT- 12345 is hereto attached asANNEX B);

5. Herein Defendant, through stealth and strategy, occupied the parcel ofland in question and refuses to vacate the same despite repeated oral andwritten demands. (Copy of the written demand is hereto attached asAnnex C);

6. The same acts of the Defendant compelled the Plaintiff to incur damagesconsisting of attorneys fees in the amount of Thirty thousand pesos(P30,000.00) pesos and filing fee, cost of transportation and other


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miscellaneous accommodation of its lawyers and other personal expensesto be incurred in attending the hearings of this case in the amount ofFIFTY THOUSAND PESOS (Php 25,000.00).

7. This action is governed by the Rules on Summary Procedure;

P R A Y E R

WHEREFORE, premises considered, it is respectfully prayed of thisHonorable Court that, after the proceedings, judgment be rendered in favor ofthe Plaintiff and ordering the Defendant and all persons claiming rights underhim to:

(a) Permanently VACATE the premises in question and give the immediateright of possession to the Plaintiff;

(b)Pay plaintiff the amount of Thirty Thousand Pesos (P30,000.00) by wayof attorneys fees and Twenty Five Thousand Pesos (P25,000.00), by wayof other litigation expenses; and,

(c) Pay the cost of this suit.Plaintiff prays for such other remedies and reliefs as may be deemed just and

equitable under the premises.

May 1, 2011. Quezon City, Metro Manila.

ATTY.PHOEMELA G. CRUZCounsel for Plaintiff

Quezon CityRoll of Attorneys No. 1234567

IBP No. A-1234567PTR No. A- 1234567

MCLE No. A-1234567


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VERIFICATION AND CERTIFICATIONAGAINST NON- FORUM SHOPPING

I, JUAN AYSION SANTOS, of legal age, after being duly sworn to inaccordance with law, depose and attest:

That I am the petitioner in the above-titled case; that I have caused the

preparation of the foregoing petition and understood the contents thereof, and Ihereby declare that all the allegations contained therein are true and correctaccording to my knowledge and belief.

Furthermore, I hereby certify that I have not filed nor caused to be filedany other similar case involving the same issues in the Supreme Court, Court ofAppeals or any other tribunal or agency and that, should there be any other suchcase/s that may have been filed, I hereby bind myself to inform the Court of suchfact within five (5) days from the discovery thereof.

IN WITNESS WHEREOF, I have hereunto set our hand this 1st day ofMay 2012, City of Quezon, Metro Manila, Philippines.

JUAN AYSION SANTOSAffiant

CTC No. 1234565Issued On: May 4, 2011Issued At: Quezon City

SUBSCRIBED AND SWORN to before me, in the City of Quezon, this

1st day of May 2012, City of Quezon, Metro Manila, Philippines, affiant having exhabited to me his Drivers License No. ___________, issued at Quezon City,Philippines.

ATTY. DAN B. SANNotary Public

Until December 31, 2013PTR No. A-123056

Issued at Quezon City

On January 1, 2012

Doc. No. 1;Page No. 1;Book No. 1;Series 2012.


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E J E C T M E N T ( F O R C I B L E E N T R Y )ANSWER



JUAN AYSION SANTOS,Plaintiff,



JOHN CHIU CODefendant.

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

A N S W E R

COMES NOW THE DEFENDANT JOHN CHIU CO, through theundersigned counsel, and unto this Honorable Court most respectfully submitsthat:

1. DEFENDANT ADMITS the allegations in paragraph 1 andparagraph 2 of complaint insofar as they relate to their personalcircumstances;

2. DEFENDANT specifically DENIES the allegations in paragraph 5since he was given authority byJANICE DY LEE to occupy theland.

P R A Y E R

WHEREFORE, the answering defendant, most respectfully pray

for judgment:

1. Dismissing the complaint with costs against the plaintiff; and2. The Defendants further pray for any and all relief and remedies

fitting and proper under the premises.


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City of Quezon, June 01, 2012

ATTY. SHU B. SAY

Counsel for DefendantQuezon CityRoll of Attorneys No. A-123467

IBP No.A-123456PTR No. A-1234557MCLE No. A123457

V E R I F I C A T I O N

I, JOHN CHIU CO, Filipino, of legal age, and residing at 123 Acacia St.,Fairville, Quezon City, Metro Manila after having been duly sworn in accordancewith law, hereby depose and state that I, the defendant in the present case;caused the preparation of the foregoing Answer; that I have read and understoodthe contents thereof and that the same are true and correct as to the best of ourknowledge and belief.

City of Quezon, June 01, 2012

JOHN CHIU CODefendant

CTC No. B-124843

Issued at Quezon CityOn March 3, 2012

Copy furnished:

ATTY. PHOEMELA G. CRUZQuezon City


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E J E C T M E N T ( F O R C I B L E E N T R Y )REPLY


METROPOLITAN TRIAL COURTQUEZON CITY

Branch 031




JOHN CHIU CO,Defendant.

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

REPLY

COMES NOW Plaintiff through the undersigned counsel and herebyrespectfully states that:

1. In the Defendants Answer, the said defendant stated that plaintiff allowedhim to use the premises of the lot;

2. Defendant is evidently misleading the court in denying the existence of thecause of action;

PRAYER

WHEREFORE, Plaintiff respectfully prays that judgment be rendered in hisfavor in accordance with the original prayer set forth in the plaintiffs complaint.

Quezon City. May 4, 2012

ATTY. PHOEMELA G. CRUZCounsel for Plaintiff

Quezon CityRoll of Attorneys No. A-1234567

IBP No.A-1234567


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PTR No. A-12345567MCLE No. A1234567

E J E C T M E N T ( F O R C I B L E E N T R Y )POSITION PAPER







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

POSITION PAPER FOR THE PLAINTIFF

PLAINTIFF, by counsel, unto this Honorable Office, respectfully submitsthis Position Paper in the above entitled case, and alleges that:

THE CASE

The case arose from the stealthy strategic usurpation of the defendant ofthe property of the herein plaintiff. Plaintiff now prays for the ejectment of thedefendant and the payment of damages.

FACTS OF THE CASE

1. Plaintiff JUAN AYSION SANTOS, is a resident of #123 Narra St., Fairville,Quezon City, where they may be served with court order and otherprocesses;

2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville,Quezon City where he may be serve with summons, order and other courtprocesses;

3. Plaintiff became owners of a certain parcel of land, through a Deed of Salefrom the original owner, JANICE DY LEE.


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4. The parcel of land is situated in 129 Fairville, Barangay Pangsy, City ofQuezon, Metro Manila covered by TCT No. 12345.

5. That herein Defendant, through stealth and strategy, occupied the parcelof land in question.

6. That Defendant, despite repeated demand, refused to vacate the land.7. The same acts of the Defendant compelled the Plaintiff to incur litigation

expenses consisting of attorneys fees in the amount of THIRTYTHOUSAND (Php 30,000.00) and other litigation expenses consisting offiling fees, cost of transportation and other miscellaneous expenses to beincurred in attending the hearings of this case at TWENTY FIVETHOUSAND PESOS (Php 25,000.00).

ISSUE

1. Whether or not defendant should be ejected.2. Whether or not plaintiff is entitled to damages.

ARGUMENTS

1. Under the Rules of Court, where a person unlawfully deprives another ofhis property, an ejectment for forcible entry case may be filed against theusurper

2. Under the Civil Code, the plaintiff is entitled to moral and actual damages.

RESERVATIONS

Plaintiff respectfully reserves its right to file supplemental pleadings oradduce additional evidence in due course of the proceedings whenever necessaryand proper.

PRAYER

WHEREFORE, plaintiff prays that the reliefs prayed for in the instantcomplaint be granted.



Quezon CityRoll of Attorneys No. A-1234567IBP No.A-1234567

PTR No. A-12345567MCLE No. A1234567


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E J E C T M E N T ( F O R C I B L E E N T R Y )POSITION PAPER



Branch 031





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

POSITION PAPER FOR THE DEFENDANT

DEFENDANT, by counsel, unto this Honorable Office, respectfullysubmits this Position Paper in the above-titled case, and alleges that:

THE CASE

The is an action for Forcible Entry commenced by the Plaintiff JUANAYSION SANTOS against the defendant JOHN CHIU CO. The subject matterof this action is a piece of land identified as in #129 Fairville, Barangay Pangsy,City of Quezon, Metro Manila. Copy of TCT- 12345 Lot No. 2-A-1 situated at

Barangay Pangsy, City of Quezon under OCT No.123456 issued in the name of thelate JUANA DELA CRUZ -SANTOS registered in the Registry of Deeds of QuezonCity.

FACTS OF THE CASE

1. Plaintiff JUAN AYSION SANTOS, with residence and postal address at#123 Narra St., Fairville, Quezon City, where they may be served withcourt order and other processes;

2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville,Quezon City where he may be serve with summons, order and other courtprocesses;

3. Plaintiff became owner of a certain parcel of land, through a Deed of Salefrom the original owner, JANICE DY LEE Copy of the Deed of Sale ishereto attached asAnnex A;


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4. The parcel of land is situated in #129 Fairville, Barangay Pangsy, City ofQuezon, Metro Manila. Copy of TCT- 12345 is hereto attached asANNEXB;

5.

That as early 2002, JOHN CHIU CO took possession of the property underLot No. 2-A-1 and constructed a nipa hut thereon.

6. On April 15, 2012 the defendants were surprised that plaintiff JUANAYSION SANTOS approached and informed him that he was the lawfulowner of the land and they acquired it through a sale because their mothernever sold the said property when she was alive.

7. On May 19, 2012 the defendant received a summon from the MetropolitanTrial Court to answer for a complaint filed against them for forcible entry.On June 1, 2012 the defendant thru the undersigned counsel filed ananswer to the complaint.

8. The same acts of the Plaintiff compelled the Defendant to incur litigationexpenses consisting of filing fee, cost of transportation and othermiscellaneous accommodation of its lawyers and other personal expensesto be incurred in attending the hearings of this case, etc., fixed at FIFTYTHOUSAND PESOS (Php 50,000.00), which the Plaintiff should also beheld answerable therefore;

ISSUE

1. Whether the defendants can be ejected by forcible entry under Rule 70Section 1 of the Revised the Rules of Court.

ARGUMENTS

1. The defendants cannot be ejected on the subject land for the reason thatfor forcible entry to attach the following circumstance must concur:

(a)That the person is deprived of his property;

(b)That such deprivation is due to force, intimidation, threat, strategy orstealth; and

(c)That such person has real title over such property.

In this case, the Defendant made no deprivation of possession on thePlaintiff because the property was already in his possession and theplaintiff started to claim such land on April 2012 based on the alleged saleof JANICE DY LEE to the Plaintiff. This would only show thatdefendant was in a threat of losing the subject land which they lawfullyacquired through the permission ofJANICE DY LEE.

Moreover the plaintiff has never been in possession of such land from thetime it was acquired by the defendants. This means that plaintiff was neverin possession of the property as one of the elements of forcible entry.

RESERVATIONS


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PRAYER

WHEREFORE, defendant prays that the reliefs he prayed for in hiscomplaint be granted and any other reliefs which the court may award to theplaintiff which is just and equitable under the circumstances.


ATTY. SHU B. SAYCounsel for Defendant




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E J E C T M E N T ( F O R C I B L E E N T R Y )ARBITRATION / COMPROMISE AGREEMENT



Branch 031

JUAN AYSION SANTOS,

Plaintiff,



JOHN CHIU CO ,Defendant.

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

COMPROMISE AGREEMENT

THE UNDERSIGNED PARTIES

JUAN AYSION SANTOS,resident of #123 Narra St., Fairville, Quezon City

AND

JOHN CHIU CO,resident of #123 Acacia St., Fairville, Quezon City

AGREE as follows:

1. That JOHN CHIU CO shall pay for the rent on the property includingback rentals;

2. The plaintiff shall drop this civil case against the defendant.IN WITNESS WHEREOF, the Parties hereto have mutually and voluntarily

agreed to the above stipulations, and sign this Agreement, at theMETROPOLITAN TRIAL COURT of Quezon City, Branch 031, on this 15th day ofJuly, 2012 for the consideration and approval of the Honorable Court.

JUAN AYSION SANTOS JOHN CHIU COPlaintiff Defendant

Assisted by:


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JUSTIN C. BERN JESICA A. ASEMediator Mediation-Supervisor/Coordinator

E J E C T M E N T (UNLAWFUL DETAINER)COMPLAINT



Branch 031


-versus- CIVIL CASE No. H-12346For: EJECTMENT (UNLAWFUL DETAINER)


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

C O M P L A I N T

PLAINTIFF, through the undersigned counsel, and unto this HonorableCourt most respectfully submit this Complaint for Unlawful Detainer and insupport hereof makes the following assertion:

1. Plaintiff JUAN AYSION SANTOSs residence and postal address is at #123Narra St., Fairville, Quezon City, where they may be served with courtorder and other processes;

2. Defendant JOHN CHIU CO residence and postal address is at #123 AcaciaSt., Fairville, Quezon City where he may be served with summons, order

and other court processes;

3. Initially, the possession of property located at 129 Fairkes St., Fairville,Quezon City by the defendant was by a contract of lease with or bytolerance of the plaintiff;

4. That defendants lease expired 2 months ago;5. That defendant refused to turn over the said property even after demand

to do so is made thus, such possession became illegal;

6. Thereafter, the defendant remained in possession of the property anddeprived the plaintiff of the enjoyment thereof; and7. The same acts of the Defendant compelled the Plaintiff to incur litigation

expenses consisting of filing fee, cost of transportation and othermiscellaneous accommodation of its lawyers and other personal expensesto be incurred in attending the hearings of this case, etc., fixed at FIFTY


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THOUSAND PESOS (Php 50,000.00), which the Defendant should alsobe held answerable;

8. This action is governed by the Rules on Summary Procedure.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed unto thisHonorable Court that:

(a)After trial, judgment be rendered in favor of herein Plaintiff and orderingDefendant and all persons claiming right under him to permanentlyVACATE the premises in question and give the immediate possessionthereof to the Plaintiff;

(b)Pay plaintiff the amount of FIFTY THOUSAND PESOS (Php50,000.00),as and by way of attorneys fees;

(c) Pay plaintiff the cost of this suit.Plaintiff prays for such other remedies and reliefs as may be deemed just and

equitable under the premises.

May 10, 2012. Quezon City.




VERIFICATION AND CERTIFICATION

AGAINST NON- FORUM SHOPPING

I, JUAN AYSION SANTOS, of legal age, after being duly sworn to inaccordance with law, depose and says:

That I am the petitioner in the above-titled case; that I have caused thepreparation of the preparation of the foregoing petition and understood thecontents thereof; and I hereby declare that all the allegations contained thereinare true and correct according to my knowledge and belief.

Furthermore, I hereby certify that I have not filed nor caused to be filed a

similar case involving the same issues in the Supreme Court, Court of Appeals orany tribunal or agency, I shall inform the Court, tribunal or agency of such factwithin five (5) days thereof.

IN WITNESS WHEREOF, we have hereunto set our hand this 10th dayof May 2012, City of Quezon, Metro Manila, Philippines.


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JUAN AYSION SANTOSPlaintiff

CTC No. 1234565Issued On: March 4, 2012

Issued At: Quezon City

E J E C T M E N T ( UNLAWFUL DETAINER)ANSWER



Branch 031




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

A N S W E R

DEFENDANT, through the undersigned counsel, and unto this HonorableCourt most respectfully submit this ANSWER for Unlawful Detainer and insupport hereof makes the following assertion:

1. Defendant admits paragraphs 1 and 2 insofar as the personalcircumstances of the plaintiff and defendant are concerned;

2. Defendant specifically denies paragraph 3 of the complaint in as much asthe plaintiff allowed for the extension of the lease contract;

3. Defendant partially admits paragraph 4 and 5 in as much as he refuses toturn over the said property only because of the extension granted to himby the plaintiff;

4. The same acts of the Plaintiff compelled the Defendant to incur litigationexpenses consisting of filing fee, cost of transportation and othermiscellaneous accommodation of its lawyers and other personal expensesto be incurred in attending the hearings of this case, etc., fixed at FIFTY

THOUSAND PESOS (Php 50,000.00), which the Plaintiff should also beheld answerable therefore;

5. This action is governed by the Rules on Summary Procedure;

PRAYER


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WHEREFORE, premises considered, it is respectfully prayed unto thisHonorable Court that:

(d)After trial, judgment be rendered in favor of herein Defendant dismissingthe complaint;

(e)Pay the Defendant the amount of FIFTY THOUSAND PESOS(Php50,000.00), as and by way of attorneys fees;

(f) Pay the Defendant the cost of this suit.Defendant prays for such other remedies and reliefs as may be deemed just

and equitable under the premises.

May 16, 2012. Quezon City.

ATTY. SHU B. SAYCounsel for Defendant



VERIFICATION AND CERTIFICATIONAGAINST NON- FORUM SHOPPING

I, JOHN CHIU CO, of legal age, after being duly sworn to in accordancewith law, depose and says:

That I am the Defendant in the above-entitled case; that I have caused thepreparation of the foregoing Answer and understood the contents thereof; and Ihereby declare that all the allegations contained therein are true and correctaccording to my knowledge and belief.

Furthermore, I hereby certify that I have not filed nor caused to be filed asimilar case involving the same issues in the Supreme Court, Court of Appeals orany tribunal or agency, I shall inform the Court, tribunal or agency of such factwithin five (5) days thereof.

IN WITNESS WHEREOF, we have hereunto set our hand this 16th dayof May 2012, City of Quezon, Metro Manila, Philippines.

JOHN CHIU CODefendant

CTC No. B-124843Issued at Quezon City

On March 3, 2012


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E J E C T M E N T ( UNLAWFUL DETAINER)REPLY



Branch 031




X - - - - - - - - - - - - - - - - - - - - - - - - - - -X

REPLY

COMES NOW Plaintiff through the undersigned counsel and herebyrespectfully states that:

1. In the Defendants Answer, the said defendant stated that plaintiff allowedhim to extend the lease of the property in question;

2. Defendant is evidently misleading the court in alleging the claim in as muchas the plaintiff did not extend such lease. Neither is there any evidence ofsuch extension;

PRAYER

WHEREFORE, Plaintiff respectfully prays that judgment be rendered in hisfavor in accordance with the original prayer set forth in the plaintiffs complaint.




IBP No.A-1234567PTR No. A-12345567


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MCLE No. A1234567

E J E C T M E N T ( UNLAWFUL DETAINER)POSITION PAPER



Branch 031




X - - - - - - - - - - - - - - - - - - - - - - - - - - -X

POSITION PAPER FOR THE PLAINTIFF

PLAINTIFF, by counsel, unto this Honorable Office, respectfully submitsthis Position Paper in the above entitled case, and alleged that:

THE CASE

The case arose from the expiration of the lease agreement between theplaintiff and defendant and the latters subsequent refusal to vacate the formersproperty. Plaintiff now prays for the ejectment of the defendant and the payment

of damages.

FACTS OF THE CASE

1. Plaintiff JUAN AYSION SANTOS, with residence and postal address at#123 Narra St., Fairville, Quezon City, where they may be serve with courtorder and other processes;

2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville,Quezon City where he may be serve with summons, order and other court

processes;

3. Defendant was a lessee of the plaintitffs property in 129 Fairkes St.,Fairville, Quezon City;

4. That defendants lease expired 2 months ago


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5. That defendant refuses to turn over the said property even after demandis made;

6. The same acts of the Defendant compelled the Plaintiff to incur litigationexpenses consisting of filing fee, cost of transportation and other

miscellaneous accommodation of its lawyers and other personal expensesto be incurred in attending the hearings of this case, etc., fixed at FIFTYTHOUSAND PESOS (Php 50,000.00), which the Defendant should alsobe held answerable therefore;

ISSUE

3. Whether defendant should be ejected.4. Whether plaintiff is entitled to damages.

ARGUMENTS

1. Under the law, where a person unlawfully deprives another of his propertyas in this case, an ejectment case may be filed against the usurper.


RESERVATIONS


PRAYER

WHEREFORE, plaintiff prays that the relief he prayed for in hiscomplaint be granted and any such other relief which the court may award to theplaintiff which is just and equitable under the circumstances.




IBP No.A-1234567

PTR No. A-12345567MCLE No. A1234567


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E J E C T M E N T ( UNLAWFUL DETAINER)POSITION PAPER



Branch 031




X - - - - - - - - - - - - - - - - - - - - - - - - - - -X

POSITION PAPER FOR THE DEFENDANT

PLAINTIFF, by counsel, unto this Honorable Office, respectfully submitsthis Position Paper in the above entitled case, and alleged that:

THE CASE

The case arose from the complaint filed by the Plaintiff against thedefendant on the alleged expiration of their lease agreement.

FACTS OF THE CASE

1. Plaintiff JUAN AYSION SANTOS, with residence and postal address at#123 Narra St., Fairville, Quezon City, where they may be served withcourt order and other processes;

2. Defendant JOHN CHIU CO is a resident of #123 Acacia St., Fairville,Quezon City where he may be served with summons, order and othercourt processes;

3. Defendant was a lessee of the plaintiffs property in 129 Fairkes St.,Fairville, Quezon City;

4. That defendants lease was extended 2 months ago;5. That as a consequence of the extension, the Plaintiff allowed the

Defendant to stay for 9 months. However, the Defendant was shocked


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when a couple of weeks after the extension was made, the Plaintiff isasking him to vacate the property immediately.

6. The same acts of the Plaintiff compelled the Defendant to incur litigationexpenses consisting of filing fee, cost of transportation and other

miscellaneous accommodation of its lawyers and other personal expensesto be incurred in attending the hearings of this case, etc., fixed at FIFTYTHOUSAND PESOS (Php 50,000.00), which the Defendant should alsobe held answerable therefore;

ISSUE

1. Whether the defendant should be ejected.2. Whether the plaintiff is entitled to damages.

ARGUMENTS

1. Under the law, where a person unlawfully deprives another of hisproperty, an ejectment case may be filed against the usurper


RESERVATIONS


PRAYER

WHEREFORE, premises considered, it most respectfully prayed thisHonorable Court that the instant Case of Forcible Entry shall be dismissed forwant of basis, either in fact or in law.




IBP No.A-1234567PTR No. A-12345567

MCLE No. A1234567


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E J E C T M E N T ( UNLAWFUL DETAINER)ARBITRATION / COMPROMISE AGREEMENT



Branch 031




X - - - - - - - - - - - - - - - - - - - - - - - - - - -X

COMPROMISE AGREEMENT

THE UNDERSIGNED PARTIES

JUAN AYSION SANTOS,resident of #123 Narra St., Fairville, Quezon City

AND

JOHN CHIU CO,resident of #123 Acacia St., Fairville, Quezon City

AGREE as follows:

1. That JOHN CHIU CO shall pay for the rent on the property includingback rentals;

2. The plaintiff shall drop this civil case against the defendant.IN WITNESS WHEREOF, the Parties hereto have mutually and voluntarilyagreed to the above stipulations, and sign this Agreement, at the

METROPOLITAN TRIAL COURT of Quezon City, Branch 031, on this 16th day ofAugust, 2012 for the consideration and approval of the Honorable Court.

JUAN AYSION SANTOS JOHN CHIU COPlaintiff Defendant


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Assisted by:

JUSTIN C. BERN JESICA A. ASEMediator Mediation-Supervisor/Coordinator

Ejectment Forcible Entry Property

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