Receivership

Republic of the Philippines
12th Judicial Region

REGIONAL TRIAL COURT
BRANCH 43
KORONADAL CITY
Province of South Cotabato
Arah Mae N. Bonilla

Plaintiff
-versus- Civil Case No. 12345
For: Receivership
John C. Dela Cruz
Defendant
COMPLAINT
COMES NOW, Plaintiff, ARAH MAE N. BONILLA, through the undersigned
counsel and unto the Honorable Court, most respectfull file the Complaint,
and aver that:
1. Plaintiff ARAH MAE N. BONILLA, Filipino Citizen, of legal age, married

and a resident of Municipality of Tupi, Philippines, served with the
orders, decisions, papers and other processes of the Honorable Court in
the address of the undersigned counsel;
2. Defendant JOHN C. DELA CRUZ, Filipino Citizen, of legal age, married
and a resident of Koronadal City, Philippines;
3. That the plaintiff and the defendant were legally united in marriage on
25th of May, 2011 at the St. Anthony Parish, Koronadal City; Copy of the
Marriage Contract is hereto attached as Annex ‘’A’’;
4. That the relationship between plaintiff and defendant while at the start
was normal, was subsequently marred with irreconcilable differences
and incompatibility by defendant’s incapacity to perform his marital
obligations.
5. That the defendant failed and abused his power to administer the
conjugal partnership property;
6. That the plaintiff and defendant owns a parcel of land that was
acquired by them through the fruits of their labor, located at Brgy. Zone
III, City of Koronadal and has an area of 3,000 square meters which
has a fair market value of Three Million Pesos (P3,000,000.00);
7. That the defendant attempts to dispose the above-stated property
without the consent of the plaintiff;
8. That the produced income from the fruits of the property are in danger
of being lost, wasted, removed or materially injured unless a receiver
be appointed to protect and preserved the same;
9. That the defendant is incapable of preserving the property due to
personal interest upon it;
10. That the petitioner is willing to file a bond in the amount which
this Honorable Court may fix in favor of the defendant against whom
this receivership is presented to the effect that he, the plaintiff to the
defendant all the damages which he will sustain by reason of the
appointment of the receiver in case the plaintiff shall have procured
such appointments whithout sufficient cause, and such other bonds
which this Honorable Court may rquire her to file hereafter, as security
for such damages
PRAYER
WHEREFORE, premises considered, after due notice and hearing, it is most

respectfully prayed that:
1. An order be issued appointing a receiver;

2. That the defendant be deprive of his power to administer the property
and its proceeds, and sentencing the defendant to pay the amount of
the income from the fruits of the property he is entitled to receive;
3. Direct the defendant to pay the ATTORNEY’S FEES AND LITIGATION
EXPENSES in the aggregate amount of ONE HUNDRED THOUSAND
PESOS (P100,000.00)
4. Other reliefs as may be deemed just and equitable in the premises are
likewise paid for.
Respectfully submitted this 19th day of June 2020, in the City of Koronadal.
ATTY. NEON TRUE C. BELDIA
Roll No. 12345
IBP OR No. XXXX/12-28-16/Koronadal City
PTR No. XXXX/12-28-16/Koronadal City
MCLE Exemption No. XXXX
Valid from November 25, 2017 until Januar 2, 2021
Telephone No. 083-2542

REPUBLIC OF THE PHILIPPINES
KORONADAL CITY
VERIFICATION
I, Arah Mae N. Bonilla, of legal age, Filipino Citizen, married and a

resident of Municipality of Tupi, after having been duly sworn to in
accordance with the law, hereby say that:
1. I am the plaintiff in the above-stated case;
2. I have cause the preparation of the foregoing Complaint;
3. I have read and understand all the contents thereof and the factual
allegation contained therein are true and correct based on my personal
knowledge and on authentic documents;
4. I hereby certify that we have not commenced or caused to commenced
any other action or proceeding involving the same issue of the subject
matter with the Supreme Court, The Court of Appeals or any other
tribunal or agency and to the best of my knowledge there is no such
action or proceeding pending therein;
5. That the Complaint is no filed to harass, cause unnecessary delay or
needlessly increase the cost of litigation and;
6. The factual allegations therein have evidentiary support.
IN WITNESS WHEREOF: we hereunto affixed our signatures this 19 th day of

June 2020.
ARAH MAE N. BONILLA

Affiant
SUBSCRIBED AND SWORN to before me this 19th day of June, 2020 at
Koronadal City, South Cotabato, affiant exhibiting to me his Voter’s
Identification Card number QI12-12-1212 issued at Koronadal City on the 14 th
of June, 2014.
Doc No.:__________
Page No.:_________
Book No.:_________
Series of 2020

Receivership

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Republic of the Philippines

12th Judicial Region

Arah Mae N. Bonilla

1. Plaintiff ARAH MAE N. BONILLA, Filipino Citizen, of legal age, married

WHEREFORE, premises considered, after due notice and hearing, it is most

1. An order be issued appointing a receiver;

ATTY. NEON TRUE C. BELDIA

Roll No. 12345

IBP OR No. XXXX/12-28-16/Koronadal City

PTR No. XXXX/12-28-16/Koronadal City

MCLE Exemption No. XXXX

Valid from November 25, 2017 until Januar 2, 2021

Telephone No. 083-2542

I, Arah Mae N. Bonilla, of legal age, Filipino Citizen, married and a

IN WITNESS WHEREOF: we hereunto affixed our signatures this 19 th day of

ARAH MAE N. BONILLA

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