REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

Branch ___
xxx City

AAAAAAAAAAAAAAAA,
Plaintiff,
SCA No. __________
For: Unlawful Detainer
-versus-

BBBBBBBBBBBBBBBBB,
Defendant.
x---------------------------------------x

COMPLAINT

PLAINTIFF, by counsel, and to this Honorable Court, respectfully

alleges that:

1. The plaintiff is of legal age, Filipino, and a resident of

AAAAAAAAAAAAA;

2. The defendant is also of legal age, Filipino, and a resident of

BBBBBBB;

3. The plaintiff is the absolute owner and lessor of

CCCCCCCCCCCCC and now leased and occupied by
defendant;

4. The defendant is obligated to pay a monthly rental of fifteen

thousand pesos (P15,000), payable every 3rd of the month;

5. The defendant has failed to pay the rents of the apartment unit
for the months of August to January, which now amounts to
seventy-five thousand pesos (P75,000);

6. Without any legal justification, defendant continuously refuses to

pay the said amount despite repeated oral and written demands.
A final demand letter was sent and received personally by
defendant on DDDDDDDD, more than 5 days before the filing of
this complaint. A copy of the final demand letter to pay and
vacate the premises is hereto attached as Annex “A”.
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 WHEREFORE, plaintiff respectfully prays from this Honorable
Court that judgment be rendered for the:

a. Restitution of the above-mentioned premises be granted to

plaintiff; and

b. For the payment of P75,000, representing the arrears of rent

now overdue, with legal interest from the filing of this
complaint, and costs of this suit.

Other reliefs that may be just and equitable are likewise prayed for.

EEEEEEEEEEE City, Philippines, FFFFFFF, 2020.

GGGGGGGGG
Counsel for Plaintiff

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, HHHHH, of legal age and a resident of Dumaguete City, under

oath declare that:

1. I am the plaintiff in the above-entitled case;

2. The facts stated in the above complaint are true and correct to
the best of my knowledge and authentic records;
3. I have not 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 in them; and

2
 4. If I should learn that the same or similar action or claim has been
filed or is pending after its filing, I shall report that fact within five
(5) days to the court or where the complaint or initiatory pleading
has been filed.

February 1, 2020, XXXXXXXX City, Philippines.

HHHHHHHHHHHHHH

SUBSCRIBED AND SWORN TO before me xxxxxxxxxxxxx

YYYYYYYYYYYYYY
Notary Public

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 20__;