Republic of the Philippines

Metropolitan Trial Court in Cities

Tacloban City
Branch 1

Pedro Santos,
Plaintiff,
CIVIL CASE No.12345
-versus- FOR: Unlawful Detainer

Juan Cruz,
Defendant.

x----------------------------x

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel

and unto this Honorable Court, most respectfully states that:

1. PLAINTIFF Pedro Santos is of legal age, Filipino, single with

residence at Brgy. 95-A Caibaan, Tacloban City.

2. DEFENDANT Juan Cruz is of legal age, Filipino, single and

likewise residing at Brgy. 95-A Caibaan, Tacloban City.

3. All parties have the capacity to sue and be sued and may be
served with summons and other legal processes.

4. The plaintiff is the owner of a land over which an apartment is

constructed located in Brgy. 95-A Caibaan, Tacloban City.

5. By virtue of a contract of lease hereto attached as “Annex A”,

the plaintiff leased unto the defendant the aforesaid apartment
for a consideration of P6,500.00 a month as rental to be paid on
or before the SEVENTH (7th) day of each month starting March
5, 2019.

6. The defendant failed to pay the agreed rental starting May 2019
up to present.

7. On June 5, 2019, 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 B”.
 8. Despite said letter of demand and repeated demands through
phone calls and texts, the defendant failed and still refused to
pay the agreed amount of rentals and to vacate the apartment.

9. By reason of the failure of the defendant to vacate the premises

and to pay unpaid rentals, the plaintiff was compelled to file this
complaint engaging the services of counsel in the amount of
P15,000.00.

WHEREFORE, premises considered, plaintiff respectfully prays

that judgment be rendered ordering defendant:

1. To vacate the subject premises;

2. To pay the unpaid rentals of P6,500.00 per month as
compensation for the reasonable use of the property until
they finally vacate said premises;

3. To pay the plaintiff the costs of suit.

Tacloban City, June 20, 2019.

ATTY. MARIA REYES

Counsel for the Plaintiff
Roll No. 125656
IBP No. 64139, issued
on January 2015 at
Tacloban City
PTR No. 3294 issued
On July 2016 at
Tacloban City
 VERIFICATION AND CERTIFICATION AGAINS FORUM
SHOPPING

I, Pedro Santos, of legal age and with residence at Brgy. 95-A

Caibaan Tacloban City, after having been duly sworn, depose and
say:

1. That I am the plaintiff in the above entitled complaint;

2. That I have caused the preparation of said complaint;
3. That I have read the allegations therein contained , and that the
same are true and correct of my personal knowledge and/or
based on authentic records.

That I have not theretofore commenced any action or filed any

claim 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. And if I should thereafter
learn that the same or similar action or claim is pending, I shall
report that fact within five (5) days therefrom to the court
wherein the aforesaid complaint or initiatory pleading has been
filed.

Witness my hand this 23rd day of June 2019 at Tacloban City,

Philippines.

PEDRO SANTOS
Affiant

SUBSCRIBED AND SWORN to before me this 25th day of June

2019, in the City of Tacloban, affiant exhibiting to me his Driver’s
License No. 789164 issued by the Land Transportation Office on
August 21, 2017 at Tacloban City.

ATTY. JUNE VER

Notary Public
Until December 2021

Doc No.
Page No.
Book No.
Series of 2019.