REPUBLIC OF THE PHILIPPINES

FIRSTJUDICIALREGION
REGIONAL TRIAL COURT
Cordillera Administrative Region
Branch 14, Baguio City
MAY NACY C. YSAWSAW,
Plaintiff,
Civil Case No. 444- 4-D
- versus For: Ejectment
AIS KWAIT E. RERE,
Accused.
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COMPLAINT
COMES NOW, plaintiff, by counsel and unto this Honorable Court,
respectfully states that:
1. 1. Plaintiff is a Filipino, of legal age, Filipino Citizen, married, with
residence at No. 868 Princess Aurora St. Fairyland, Baguio City
where she may be served with summons and other processes;
Defendant is also a Filipino, of legal age and resident of 2 Tukak,
BGH Compound, Baguio City, where he may be served with
summons and other processes;
2.

Plaintiff owns that apartment complex located at 2741 Pines

Home Compound, Paterno St, Baguio City which a part thereof,
particularly the basement it leased to defendant under the terms
and conditions stated in the Contract of Lease dated 21 February
2015, which contract expires on 21 February 2016. A copy of the
contract is attached as ANNEX A;

3. Upon expiration of the contract, plaintiff informed defendant of its

intention not to renew the lease as it would renovate the property
a; plaintiff then asked defendant to vacate the premises. A copy of
plaintiffs letter to defendant is attached as ANNEX B;
4. Despite demand duly made and received, defendant has refused
to vacate the premises and continues to occupy the property
without plaintiffs consent;
5. Resort to the Barangay conciliation system proved useless as
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defendant refused to appear before the Lupong Tagapamayapa. A

Certification to File Action is attached as ANNEX C;
6. Defendants act of dispossession has caused plaintiff to suffer
material injury for which plaintiff suffered legal expenses on
account of the initial payment made to the contractor amounting to
ONE HUNDRED THOUSAND PESOS (100,000.00 Php) which
was according to the terms of agreement entered to between the
plaintiff and the contractor , non-refundable, such fact is evidenced
in the Contract between the plaintiff and FVS Builders Inc.
attached herein as ANNEX D.
WHEREFORE, plaintiff respectfully prays for judgment in its favor
by ordering defendant to vacate the property and peacefully turn over
possession to plaintiff and for defendant to pay plaintiff the amount of
ONE HUNDRED THOUSAND PESOS (100,000.00 Php) representing
the payment made to FVS Builders and SIXTY THOUSAND PESOS
(60,000.00 Php) for Attorneys fees.
Other just and equitable reliefs are also prayed for.
This 10th day of March 2016, in the City of Baguio, Philippines.

ATTY. OSMOND VOM HAMBLIN

Counsel for Plaintiff
th
9 Chow Echo Suite, 3 North Drive, Baguio City
Telephone No. (074) 444- 3322
PTR No. 23456; 1/2/2019; Baguio City
IBP OR No. 909099; 2/04/2018; Baguio City Chapter
Attorneys Roll No. 60000; 09/22/2018
MCLE Compliance No. VI-7878787; 01/1/2017

REPUBLIC OF THE PHILIPPINES

DONE: IN THE CITY OF BAGUIO
S.S.

}
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VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, MAY NACY C. YSAWSAW, of legal age, after having been duly
sworn in accordance with law, depose and state that:
1. I am the complainant in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are
true and correct of my personal knowledge and/or on the basis of
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copies of documents and records in my possession;

4. I attest to the authenticity of the annexes hereof;
5. I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;
6. To the best of my knowledge and belief, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;
7. If I should thereafter learn that a similar action or proceeding has been
filed or is pending before the Supreme Court, the Court of Appeals, or
any other tribunal or agency, I undertake to report that fact within five (5)
days therefrom to this Honorable Court.
IN WITNESS WHEREOF, I have hereunto affix my signature this
25 day of March 2016 in the City of Baguio, Philippines.
th

MAY NACY C. YSAWSAW

Affiant
Drivers License No. 7272727
Issued: 2/29/2008; Baguio City
SUBSCRIBED AND SWORN to before me, in the City of Baguio,
this 10th day of March 2016, by the affiant who has satisfactorily proven
his identity to me through his Drivers License indicated below his name,
that he is the same person who personally signed the foregoing
document before me and who acknowledged that he executed the
same.
Doc. No 14
HENRIETTA
Page No. 03
TANGONAN
Book No.2
LASUDEN

BAGUIO
CITY,
PHILIPPI
Series of 2016

ATTY. HENRIETTA TANGONAN LASUDEN

NOTARY PUBLIC
Until December 2020
4th Floor Jose De Leon Building,
38 Upper Session Road, Baguio City
Telephone No. (074) 442- 7845
PTR No. 89898; 2/14/2018; Baguio City
IBP OR No. 642741; 1/04/2017;
Baguio City Chapter
Attorneys Roll No. 62741; 09/12/2020
Commission Serial No.: 44-JH-14
MCLE Compliance No. VI-4567890; 02/21/2018
TIN No. 436-820-438-000

Page 3 of 3

Notary Public
Roll No. 62741