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Republic of the Philippines

Province of Negros Occidental
City of Bacolod
Barangay Taculing

OFFICE OF THE LUPONG TAGAPAMAYAPA

Otto Potato and Barangay Case No. 23133

Imogen Pots For: Trespassing to Property
Complainants, and Usurpation of Rights

— against —

JOSE BONIFACIO and

ANDRES RIZAL
Respondents.

COMPLAINT

WE hereby complain against above named respondents for violating

our rights and interests in the following manner:

1. That we are the registered owner of parcels of land located at Brgy.

Taculing, City of Bacolod, Philippines with a total combined area of
TWO AND ONE-HALF HECTARES (2.50) evidenced by the herein
attached TCT Nos. 123213-22;

2. That on January 15, 2019, respondents JOSE BONIFACIO and ANDRES

RIZAL, by way of threat and intimidation, forcefully occupied our land
and immediately thereafter took possession of the said land by
cultivating and sowing palay seeds;
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3. That respondents employed persons who prevented us from entering

our property and up to this time, we cannot freely enter and fully
cultivate our land;

4. That respondents are residents of this barangay, Barangay Taculing,

and the subject property is likewise located in the same barangay,
making the instant complaint cognizable and under the jurisdiction of
Brgy. Taculing, City of Bacolod, as provided for under R.A. No. 7610.

THEREFORE, WE pray that the following reliefs be granted to us in

accordance with law and/or equity:

1. That respondents JOSE BONIFACIO and ANDRES RIZAL be made to

appear before the Lupong Tagapamayapa of Brgy.Taculing, Bacolod
City, Philippines;

2. That after notice and hearing, respondents be directed to vacate our

properties;

3. Other reliefs just and equitable are likewise prayed for.

Made this 15th day of February, 2019.

_________________ _________________
Otto Potato Imogen Pots
(Complainant) (Complainant)

Received and filed this ___ day of June, 2018.

____________________________
Punong Barangay/Lupon Chairman