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Republic of The Philippines Fourth Judicial Region Regional Trial Court BRANCH - Hall of Justice Pallocan West, Batangas City

Annalyn De Chavez filed a complaint against Angelica Landicho for specific performance. De Chavez agreed to buy Landicho's Honda Jazz for 850,000 pesos via social media on March 10, 2019, with delivery and payment scheduled for April 1, 2019. However, on the scheduled date, Landicho did not show up or respond to De Chavez's messages. As a result, De Chavez requests the court to compel Landicho to complete the sale, deliver the car, and accept payment, in addition to paying attorney's fees and court costs.

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78 views

Republic of The Philippines Fourth Judicial Region Regional Trial Court BRANCH - Hall of Justice Pallocan West, Batangas City

Annalyn De Chavez filed a complaint against Angelica Landicho for specific performance. De Chavez agreed to buy Landicho's Honda Jazz for 850,000 pesos via social media on March 10, 2019, with delivery and payment scheduled for April 1, 2019. However, on the scheduled date, Landicho did not show up or respond to De Chavez's messages. As a result, De Chavez requests the court to compel Landicho to complete the sale, deliver the car, and accept payment, in addition to paying attorney's fees and court costs.

Uploaded by

aldeh
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH ____
HALL OF JUSTICE
PALLOCAN WEST, BATANGAS CITY

ANNALYN DE CHAVEZ,
Plaintiff,

-versus- Civil Case No: ____________


For: Specific Performance
ANGELICA LANDICHO,
Defendants.

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

COMPLAINT
COMES NOW Plaintiff, by undersigned counsel, unto this Honorable
Court, most respectfully states that:
1. Plaintiff is of legal age, married, Filipino citizen and a resident of
Balagtas, Batangas City where she may be served with summons and other
court processes;
2. Defendant is of legal age, married, Filipino citizen and a resident of
Kumintang Ibaba, Batangas City where she may be served with summons
and process of this Honorable Court;
3. On March 10, 2019 the herein Defendant posted online through
social media, in http://www.facebook.com specifically, that she is selling
her pre-owned Honda Jazz. Attached herewith is the photo copy of the post
by the Defendant marked as Annex “A”;
4. Plaintiff inquired with the Defendant through the said social media
with an intention of buying the said motor vehicle. And on the same day,
Plaintiff and Defendant reached a perfected consensual agreement on the
price of the motor vehicle to the amount of EIGHT HUNDRED FIFTY
THOUSAND (P850,000.00) PESOS and apart from the price, that the
payment and delivery of the car would be on April 1, 2019 near SM
Batangas. Attached herewith is the photo copy of the agreement marked as
Annex “B”;
5. On April 1, 2019 when the Plaintiff went to SM Batangas, the
Defendant, despite repeated demands and tender of payment through a
cellular phone by the Plaintiff, did not show up on the agreed location nor
replied to the relayed messages of the plaintiff;
6. As of to the date of filing this complaint, the Plaintiff has yet to
receive any word nor the object of the sale from the Defendant.
8. That by reason of Defendant’s unjustified failure to appear on the
agreed date of sale, despite repeated demands, Plaintiff was constrained to
engage the services of counsel for a fee of TEN THOUSAND (Php10,000.00)
PESOS plus THREE THOUSAND FIVE HUNDRED (Php3,500.00) PESOS per
court appearance as actual damages;
PRAYER
WHEREFORE, it is most respectfully prayed of this Honorable Court
that after due notice and hearing, judgment be rendered in favor of Plaintiff
and against defendant ordering the latter, as follows:
1. To compel the Defendant to forego with the sale, deliver the car and
accept the payment;
2. To pay Attorney’s fees TEN THOUSAND (Php10,000.00) PESOS plus
THREE THOUSAND FIVE HUNDRED (Php3,500.00) per court
appearance;
3. To pay cost of the suit.
Other relief and remedies that are just and equitable under the
premises are likewise prayed for.
Batangas City, ______________.

By:

ATTY. MARIA ACONTE


Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97:
Pallocan West, Batangas City
REPUBLIC OF THE PHILIPPINES)
BATANGAS CITY )S.S.

VERIFICATION AND CERTIFICATION


OF NON-FORUM SHOPPING

I, Annalyn De Chavez, of legal age, after having been duly sworn in


accordance with law, depose and state that:
1. I am the plaintiffs in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are
true and correct of my personal knowledge and/or on the basis of
copies of documents and records in my possession;
4. I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any
other tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals,
or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has
been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, we undertake to report
that fact within five (5) days therefrom to this Honorable Court.

Annalyn De Chavez
Affiant

SUBSCRIBED AND SWORN to before me this 12 th day of April, 2020


at Rosario, Batangas affiant exhibiting to me his Driver’s License with
No.DOJ-01-0087.

Doc. No. ;
Page No. ;
Book No. ;
Series of 20__.

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