Republic of the PhilippinesREGIONAL TRIAL COURTJudicial RegionBranch ___ Legaspi City

CorazonCIVIL CASE No. _______________Plaintiff,

versusFOR: Damages for desecration of dead body, moral damages and attorneys feePedroDefendantx- - - - - - - - - - - - - - - - - - - - - - - x

COMPLAINT

COMES NOW Plaintiff, by counsel and to this Honorable Court, respectfully states that:1.Plaintiff Corazon is of legal age, Filipino, married, and a resident of Pototan, Legaspi City, Philippines For purposes of this action, plaintiff may be served with all orders, notices, and other processes of this Honorable Court through the office address of the undersigned counsel indicated below;2.Defendant Pedro, of legal age, Filipino, single, and may be served with summons and other processes of this Honorable Court at his last known address at Kamyas, Legaspi City, Philippines;3.Sometime on January 15, 2015, Plaintiffs daughter, Maria died due to severe pneumonia. 4.She has been interred on January 20, 2015.5. On January 25, 2015, herein defendant, who is the caretaker of the cemetery Malapuyot, exhumed the body of Maria and had a brutal sexual intercourse with the body. 6. Hence, this suit instituted by the Plaintiff as provided for under Article 309 of the New Civil Code,Any person who shows disrespect to the dead, or wrongfully interferes with a funeral shall be liable to the family of the deceased for damages, material and moral.7.A true and faithful photographs shot while defendant was having sexual intercourse with the corpse are attached hereto as annex A;8.Consequently, Plaintiff was constrained to engage the services of counsel to whom it obligated itself to pay as Attorney's Fees the amount equivalent to _____________ (______%) percent of the total amount due from Defendant to Plaintiff.

PRAYER

WHEREFORE, after due notice and hearing, Plaintiff respectfully prays that judgment be rendered against the Defendant as follows:1.Ordering the Defendant to pay Plaintiff the sums of:a. _____________ (_____%) percent of the total amount due as material and moral damages;b._____________ (_____%) percent of the total amount due as Attorney's Fees plus Appearance Fee at the rate of P__________ per court hearing / conference;d.The costs of suit.

2.Plaintiff respectfully prays for such other reliefs as may be just and equitable in the premises.

Date _____________, Philippines, __Date__.

(COUNSEL)

VERIFICATION AND CERTIFICATION

Republic of the Philippines)Province of Sorsogon) S.S.City of Legaspi)x - - - - - - - - - - - - - - - - - - - - - - - x

I, Corazon, of legal age, Filipino, married, and a resident of Pototan, Legaspi City, Philippines, after being sworn in accordance with law, hereby depose and say:

That I am the Plaintiff in the above-entitled case; That I have caused the preparation of the above Complaint and I have read the same and knows the contents thereof; That the allegations contained therein are true and correct of my own personal knowledge.

That I further certify that: (a) I have not theretofore commenced any other action or proceeding or filed any claim involving the same issues or matter in any court, tribunal, or quasi-judicial agency and, to the best of my knowledge, no such action or proceeding is pending therein; (c) if I should thereafter learn that the same or similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or any other tribunal or quasi-judicial agency, I undertake to report such fact within five (5) days therefrom to the court or agency wherein the original pleading and sworn certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this _____________ at _____________, Philippines.

AFFIANT

SUBSCRIBED AND SWORN to before me, this _____________, by _____________ who exhibited to me her Taxpayer Identification No. _____________ issued at _____________, Philippines on _____________.

Notary Public