Short answer. A verified complaint stating with certainty the right and purpose of expropriation, describing the property sought to be expropriated, and joining as defendants everyone owning, claiming to own, or occupying any part or interest in it, showing each defendant's separate interest as far as practicable.
What the law says
The right of eminent domain shall be exercised by the filing of a verified complaint which shall state with certainty the right and purpose of expropriation, describe the real or personal property sought to be expropriated, and join as defendants all persons owning or claiming to own, or occupying, any part thereof or interest therein, showing, so far as practicable, the separate interest of each defendant.
Rule 67, Section 1 — The complaint. Read the full provision →
Certainty about the right and purpose
The exercise of eminent domain begins with a verified complaint, and that complaint cannot be vague about why the government wants the property. It must state with certainty both the legal right being invoked and the specific purpose behind the expropriation, so the property owner knows exactly what is being taken and why. The verification requirement itself signals that these are not casual allegations — the plaintiff swears to their truth from the outset.
Describing the property and joining everyone with a stake
The complaint must describe the real or personal property sought to be expropriated, and it must join as defendants all persons owning, claiming to own, or occupying any part of it or any interest in it, showing, so far as practicable, each defendant's separate interest in the property. Casting the net this wide is meant to bring every stakeholder into the same proceeding, so the compensation question is resolved once rather than through a string of separate suits.
When ownership is unclear
The rule also anticipates murkier situations: if title to the property appears to be in the Republic of the Philippines even though private individuals occupy it, or if title is otherwise obscure or doubtful so the government cannot say with accuracy who the real owners are, the complaint must state that fact expressly rather than guess. Requiring honesty about uncertain title up front avoids a complaint that quietly assumes an ownership picture the government cannot actually verify.
Why these contents are required upfront
Requiring certainty, a full property description, and complete joinder of interested parties at the complaint stage front-loads the disputes that would otherwise surface piecemeal later in the case. A defendant reading the complaint should be able to tell immediately what is being taken, why, and whether their own interest in the property has been recognized, rather than discovering gaps or ambiguities only after the proceeding is already underway.
Related provisions
- Rule 67, Section 1 — The complaint
- Rule 67, Section 4 — Order of expropriation
- Rule 67, Section 13 — Recording judgment, and its effect