REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT FIRST JUDICIAL REGION BRANCH 19 Bangui, Ilocos Norte REPUBLIC OF THE PHILIPPINES represented by DEPARTMENT OF ENERGY (DOE), Plaintiff, -versus- THE UNKNOWN HEIRS OF FELIPE RANJO, and the MUNICIPAL ASSESSOR OF PASUQUIN, ILOCOS NORTE, ET.AL., Defendants, CIVIL CASE NO. 2391-19 X - - - - - - - - - - - - - - - - - - X AMENDED COMPLAINT (With Urgent Prayer for the Issuance of a Writ of Possession) (Summons by Publication) PLAINTIFF, by counsel, respectfully states: 1. Plaintiff Republic of the Philippines, represented by the Department of Energy (DOE), is a sovereign political entity with the inherent power to expropriate private property for public use upon payment of just compensation. It may be served with court processes through its statutory counsel, the Office of the Solicitor General (OSG), at 134 Amorsolo Street, Legaspi Village, Makati City. 2. Private defendant
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