Complaint For Ejectment or Unlawful Detainer

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COMPLAINT

COMES NOW the plaintiff, by the undersigned counsel, and unto this Honorable
Court, respectfully alleges:

1. That the plaintiff is of legal age and presently residing at


_________________________, while the defendant is also of legal age and residing at
__________________________;

2. That the plaintiff is the absolute owner and lessor of that certain residential
house located at ______________, and now leased and occupied by the defendant;

3. That the defendant leases and occupies the said residential house under the
express obligation of paying a rent of Php _______ a month, payable in advance within
the first five (5) days of every month;

4. That the defendant has not paid the rents for the said residential house for the
months of ________ and __________ of the current year;

5. That furthermore, the defendant has failed to comply with the conditions of his
lease, namely, __________________________;

6. That the plaintiff has several times demanded of the demanded to vacate the
above premises and to pay his back rentals, now amounting to Php ________, the last
demand having been made on him personally and in writing on ________ or more than
five (5) days before the filing of this complaint.

WHEREFORE, it is respectfully prayed that, after due hearing, judgment be


rendered in favor of the plaintiff:

(a) For the restitution of the above mentioned premises;

(b) For the payment of ___________________________ Pesos (Php ________),


representing the arrears of rent now overdue, with legal interest from the filing of the
complaint, and costs of this suit;

(c) For attorney's fees in the amount of ___________________________ Pesos


(Php ________).

City of Manila, on this ____ day of _________, 20___.

___________________
Counsel for the Plaintiff
_____Address_______________
_____IBP No._______________
_____Roll No._______________
_____MCLE Compliance No.___

VERIFICATION AND JURAT

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