REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

City of Davao
Branch 5

KRUL ACOSTA,
Plaintiff, CIVIL CASE No. 98765
FOR: Unlawful Detainer
-versus-

MEGAN VITUG,
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most respectfully
avers:
1. That the plaintiff, KRUZ ACOSTA, is of legal age, Filipino citizen, single, with residence and postal address
at 123 Benitez Street, Cabantian, Davao City;
2. That the defendant, MEGAN BANTUGAN, is of legal age, Filipino citizen, single, with residence and postal
address at 456 Moderitso Street, Cabantian, Davao 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 654 Benitez Street,
Cabantian, Davao City;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid apartment for a
consideration of P5,000.00 a month as rental to be paid within the first ten (10) days of each month starting
November 3, 2020;
5. The defendant failed to pay the agreed rental for several months starting February 19, 2021 up to the present;
6. On May 3, 2021, 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 P10,000.00.
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 P5,000.00 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.

City of Davao, September 24, 2021.

Sgd. ATTY. GLENE A. NALLA

Counsel for the Plaintiff
Mastergan Street, Cabantian, Davao City
 VERIFICATION/CERTIFICATION OF FORUM SHOPPING
Republic of the Philippines )
City of Manila ) S.S.
I, KRUZ ACOSTA, of legal age, Filipino citizen, single and resident of 123 Benitez Street, Cabantian, Davao
City, after having been duly sworn to in accord Nance 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. The 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 6TH of September 2021, in the City of
Davao.

KRUZ ACOSTA

SUBSCRIBED AND SWORN to before me this 6th day of October, 2021, in the City of Davao, affiant
exhibiting to me his Driver’s License No. 12345 issued by the Land Transportation Office on April 8, 2019 at
the City of Davao. That he is the same person who personally signed the foregoing affidavit before me and
acknowledged that he/she executed the same.

ATTY. GLENE A. NALLA

Notarial Commission No. 2020-000-0000
Commission Expires December 20, 2021
Notary Public / Roll of Attorney No. 00000
I.B.P. No. 0000000 ; 4/5/2019; Davao City
P.T. R. No. 0000000G;5/4/2019; Davao City
Mastergan Street, Cabantian, Davao City

Doc. No. ________

Page No. _______
Book No. _______
Series of 2021.