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Complaint
Complaint
Dopey Dwarf,
Plaintiff,
CIVIL CASE No. 678
-versus- FOR: Unlawful Detainer
Snow White,
Defendant.
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COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1. That the plaintiff, Dopey Dwarf, is of legal age, Filipino citizen, single, with residential
address at 2128, P. Burgos St., Pasay City.
2. That the defendant, Snow White, is of legal age, Filipino citizen, single, with
residential address at 123, Zamora, Pasay City where they may be served with summons
and other court processes;
3. The plaintiff is the owner of a land over which an apartment had been constructed
located at 10, College Rd., Pasay City;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid
apartment for a consideration of P8,000.00 a month as rental to be paid within the first
ten (10) days of each month starting August 1, 2015;
5. The defendant failed to pay the agreed rental for several months starting January 2016
up to the present;
6. On March 1, 2016, the plaintiff sent a letter of demand to vacate the apartment which
was received by the defendant as shown in the registry return receipt hereto attached as
Annex “A”;
7. Despite said letter of demand which was repeated by oral demands, the defendant
failed and still refused to pay the agreed amount of rentals and to vacated the apartment;
8. By reason of failure of the defendant to vacate the premises and to pay the unpaid
rentals, the plaintiff was compelled to file this complaint engaging the services of counsel
in the amount of P20,000.00.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed unto this
Honorable Court that, after hearing, judgment be rendered ordering the defendant:
1. To vacate the subject premises;
2. To pay the amount of P8,000.00 per month as compensation for the reasonable use of
the subject premises until they finally vacate the said premises;
3. To pay the plaintiff the cost of the suit.
By:
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Atty. Kichelle May Ballucanag
Roll of Attorney No. 54321
IBP No. 98765/05-14-15/Manila
I, DOPEY DWARF, of legal age, Filipino citizen, single and resident of 2128, P. Burgos St.,
Pasay City, after having been duly sworn to in accordance with law do hereby depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and have read the allegations
contained therein;
3. That allegations in the said complaint are true and correct of my own knowledge and
authentic records;
4. I hereby certify that I have not commenced any other action or proceeding involving the same
issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no
such other action or claim is pending therein;
5. That if I should learn thereafter that a similar action or proceeding has been filed or is
pending, I hereby undertake to report that fact within five (5) days therefrom to the court or
agency where the original pleading and sworn certification contemplated herein have been
filed;
6. I executed this verification/certification to attest to the truth of the foregoing facts and to
comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 11th of July 2016, in the City of
Pasay.
Dopey Dwarf
Affiant
SUBSCRIBED AND SWORN to before me this 11th day of July 2016, in the City of Pasay,
affiant exhibiting to me his Driver’s License No. 5555 issued by the Land Transportation Office on
January 4,2016 at the City of Manila.
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