Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

PETITION

COMES NOW, petitioner ________________________________ through counsel, unto this Honorable Court, respectfully alleges:

1. That he is the special administrator of the estate of ______________, deceased;

2. That the deceased, during his lifetime, executed a certain deed of sale of a piece of real estate in favor of the respondent, dated ___________, and particularly described as follows, to wit: ___________________________________ ;

3. That the said sale is forged and fictitious, and is therefore in truth and in fact invalid;

4. That the existence of the said alleged deed of sale is prejudicial to the title of the lawful heirs of the deceased upon the above-described real property;

5. That equity demands that the said deed of sale be surrendered and cancelled, as it is a cloud upon the title of the deceased and his lawful heirs.

WHEREFORE, it is respectfully prayed that:

1. ______________________________________________________________

2. ______________________________________________________________

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.

______ _____________ 20___

City of _____________ .

_______________________________________

Counsel for the Petitioner