ROGER F. FEDERER,
Plaintiff,
-versus- CIVIL CASE NO.:2017-8148
RAFAEL U. NADAL, For: Ejectment
Defendant,
x----------------------------------------x
COMPLAINT
COMES NOW, the plaintiff, unto this Honorable Court, most respectfully avers:
1. Ordering the defendant, and all persons claiming right under them to vacate the
subject premises/portion of the lot;
2. Ordering the defendant to pay the amount of Php 24,000.00 per month as
compensation for the reasonable use of the subject portion of the lot/premises
until they finally vacate the said premises;
3. Ordering the defendant to pay the plaintiff the amount of Php 150,000.00 as
moral damages, and Php 100,000.00 as exemplary damages;
4. Ordering the defendant to pay the cost of the suit.
Plaintiff likewise prays for such other reliefs that are deemed just and equitable
under the premises.
By:
2. I have read and understood the contents hereof of this Complaint, and the facts
herein alleged are true and correct of my own knowledge and based on available
verifiable records;
3. I heretofore have not commenced any other action or proceeding or any claim
involving the same issues raise in the above-captioned case, in this Honorable Supreme
Court, in the Court of Appeals, nor the different Divisions thereof, nor in any other court
or tribunal or agency and, to the best of my knowledge, no such other action or claim is
pending therein.
4. I hereby undertake to notify this Honorable Court of such fact within five (5)
days from receipt of such knowledge, should I come to learn that the same or a similar
action or claim has been filed or pending in the Supreme Court, Court of Appeals, the
different Divisions thereof, or any other court or tribunal or agency;
ROGER F. FEDERER
Affiant
I, Andy Murray, Filipino, married to Maria Sharapova, of legal age, with residence and
post-office address at #1013 Bakhawan Residence, Bacan, Aklan for and in
consideration of the sum of One million five hundred thousand PESOS (P1,500,000.00) ,
Philippine currency, to me in hand paid by
ROGER F. FEDERER
Filipino, of legal age, with residence and post-office address at #800 Oyo Torong Avenue,
Kalibo, Aklan;
_________________
Andy Murray
With my consent:
_________________
Maria Sharapova
ANNEX D
June 2, 2017
I am writing you this letter in connection to vacate the land, registered under TCT
No.T-116888, located at No. 96 Osmena Avenue, Capitol Site, Estancia, Kalibo, Aklan
that you are occupying. I am the new registered owner of the said land and; in this regard,
legal demand is hereby being made for you to vacate the lot within fifteen (15)
days from receipt of this letter. Otherwise, I will have to avail of the appropriate legal
remedy in order to protect my rights and interest.
Roger F. Federer