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11.
To serve as deterrent to the commission by other persons of similar
acts in violation of the law and breach of contractual obligations and to
provide an example for the public good, Respondent must be held liable for
payment of exemplary damages in the amount of FIFTY THOUSAND
PESOS (Php 50,000.00).
THIRD CAUSE OF ACTION
10 . The foregoing allegations are reproduced herein by reference.
11 . In order to institute this action against Respondent, in the exercise and
protection of her rights, Complainant was constrained to engage the
services of counsel for a fee and to incur expenses of litigation in the
amount of SIXTY THOUSAND PESOS, which should be charged against
Respondent.
RELIEF
WHEREFORE, it is respectfully prayed that:
a. Upon due proceedings, Respondent be ordered to issue the Original
Certificate of Title in the name of ________________ Or in the
ALTERNATIVE
b. To refund in FULL the purchase price received for the subject
property in accordance with the Supreme Court ruling in the case of
CASA FILIPINA DEVELOPMENT CORPORATION, vs. DEPUTY
EXECUTIVE SECRETARY, OFFICE OF THE PRESIDENT,
MALACAANG, MANILA, AND JOSE VALENZUELA, JR., G.R.
No. 96494, May 28, 1992
c. Further, to render judgment in favor of Complainant by:
1. Ordering Respondent to pay complainant FIFTY
THOUSAND PESOS (Php 50,000.00) as exemplary
damages;
2. Ordering Respondent to pay complainant SIXTY
THOUSAND PESOS (Php 60,000.00) as attorneys fees and
expenses of litigation; and
3. Ordering Respondent to pay the cost of the suit.
Other equitable reliefs are likewise prayed for.
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NOTARY PUBLIC
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