Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

6th Judicial Region
Branch 8
Iloilo City

SPOUSES NELSON CIVIL CASE No. _______

and ABBY LIM,             FOR: Unlawful Detainer
Plaintiffs,
                                    
-versus-                                            

SPOUSES CAMACHO,
                         Defendants.
x--------------------------------------x

COMPLAINT

  COMES NOW, the plaintiffs, through the undersigned

counsel and unto this Honorable Court, most respectfully
aver:

1. That the plaintiffs, NELSON AND ABBY LIM, are of legal

age, Filipino citizens, married to each other, with
residence at 94 Delgado Street, Iloilo City;

2. That the defendants, SPOUSES TITO AND TITA

CAMACHO, are of legal age, Filipino citizens, married,
with residence at Cabatuan, Iloilo, where they may be
served with summons and other court processes;

3. The plaintiffs are the owners of a 3-hectare parcel of land

located in Brgy. Abilay, Oton, Iloilo;

4. By virtue of a contract of lease, the plaintiffs leased unto

the defendant the aforesaid parcel of land for a
consideration of Twenty Thousand Pesos (P20,000.00)
per month for a period of five (5) years, as rental to be
paid every first day of each month starting August 1,
2006 until July 31, 2011;
 5. The contract of lease stipulates that the defendants turn
over the possession of the said property to the plaintiffs
at the time of the expiration of the contract without need
of demand;

6. The defendants wrote a letter to the plaintiffs on July 15,

2011 expressing their desire to continue the lease;

7. Said letter includes two (2) checks amounting to Two

Hundred Forty Thousand Pesos (P240,000.00),
representing the rentals for one (1) year, or from August
1, 2011 to July 31, 2012 and from August 1, 2012 to
July 31, 2013;

8. Upon receipt of the letter, the plaintiffs wrote back the

defendants refusing the defendants’ request for extension
of the lease because the former wanted to take
possession of the lot, returning the two (2) checks and
demanded the latter to vacate the leased premises;

9. On August 3, 2011, plaintiff NELSON LIM visited the

leased premises and saw defendant TITO CAMACHO
working on the land with his men and is still in
possession thereof;

10. By reason of failure of the defendant to vacate the

premises, the plaintiffs were compelled to file this instant
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 defendants:

1. To vacate the subject premises;

2. To pay the amount of P20,000.00 per month as
compensation for the reasonable use of the subject
premises until they finally vacate the said premises;
3. To pay the plaintiffs P10,000.00 as attorney’s fees.
4. To pay the plaintiffs the cost of the suit.

City of Iloilo, December 14, 2013.

 Atty. Genghis Khan
Counsel for the Plaintiff
Khan Law offices
2 Floor, AJL Building,
nd

Gen. Luna Street, Iloilo City

Until December 31, 2014
Roll of Attorney No. 50199
PTR No.9876543/January2,2014/Iloilo City
IBP No.546782/January 2, 2014/ Iloilo City
MCLE Compliance No. IV-6401649

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Iloilo                     ) S.S.

  WE, NELSON and ABBY LIM, of legal age, Filipino citizens, married
and residents of 94 Delgado Street, Iloilo City, after having been duly
sworn to in accordance with law do hereby depose and say:

1. That we are the plaintiffs in the above-entitled case;

2. That we 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 our
own knowledge and authentic records;
4. We hereby certify that we 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 our knowledge, no such
other action or claim is pending therein;
5. That if we should learn thereafter that a similar action or
proceeding has been filed or is pending, we 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. We 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, we have hereunto affixed my signature this

14th of December 2013, in the City of Iloilo.

NELSON LIM ABBY LIM

Affiant Affiant
 Driver’s License No. Driver’s License No.
F03-05-648300 F03-05-648301            

SUBSCRIBED AND SWORN TO before me this 145th day of

December, 2013 in Iloilo City, Philippines, affiants exhibited to me their
respective valid proofs of identification.

ATTY. GENGHIS KHAN

Notary Public
My Commission Expires Dec. 31, 2014
Roll of Attorney No. 50199
PTR No.9876543/January2,2014/Iloilo City
IBP No.546782/January 2, 2014/ Iloilo City
MCLE Compliance No. II-6401649

Doc. No. ______;

Page No. ______;
Book No. ______;
Series of 2014.