Third Party Complaint.docx 1h1p6l

REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT 11th Judicial Region Branch 1, Davao City

PEDRO,

Civil Case No. 9876543-21 Plaintiff,

-versusJUAN, Defendant Third Party Plaintiff,. -versus-

ISABELA, Third-Party Defendant. x------------------x

THIRD PARTY COMPLAINT

COMES NOW the Third-Party Plaintiff, JUAN, by and through his undersigned counsel and pursuant to Rule 6, Sec. 11 of Rules of Court, hereby impleads the Third-Party Defendant, ISABELA and alleges as follows:

1.

Pedro, Plaintiff filed a complaint against JUAN, Defendant and Third Party Plaintiff.

2.

PEDRO alleges that the SALE of a parcel of land covered by TCT No. T-14344 with JUAN caused damage to him.

3.

JUAN, in GOOD FAITH, bought the parcel of land covered by TCT No. T-14344 from ISABELA.

4.

JUAN, in GOOD FAITH considering that the SALE between JUAN and ISABELA is free from any impediment, sold the parcel of land covered by TCT No. T-14344 to PEDRO.

5.

The parcel of land covered by TCT No. T-14344 was foreclosed by the Land Bank of the Philippines for the reason that it was mortgaged by IRANA, co- owner of the parcel of land covered by TCT No. T-14344.

6.

If PEDRO recovers against JUAN any judgment for their damages then JUAN is entitled to judgment against ISABELA for all such sums since the SALE of the parcel of land covered by TCT No. T-14344 was the sole cause of PEDRO’s damages and injuries.

WHEREFORE, it is respectfully prayed that JUAN, Defendant and Third Party Plaintiff, can demand judgment against ISABELA, Third Party Defendant, for all sums that may be adjudged against JUAN, as Defendant, in favor of PEDRO, as Plaintiff, together with all costs incidental to the defense of the principal suit.

Davao City, Philippines, March 5, 2013.

CAYAMANDA, CEPE, DELA TORRE, ORTIZ and PEREZ LAW OFFICES 1st Floor, BIG Building Bolton Street, Davao City