REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

City of Legazpi
Branch 1

MR. D,
Plaintiff
CIVIL CASE No: 56473
-versus- FOR: Unlawful Detainer

MRS. E,
Defendant

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

COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court,
most respectfully avers:
1. That the plaintiff, MR. D, is of legal age, Filipino citizen, single, with residence and postal
address at 946 Magallanes Street, Legazpi City;
2. That the defendant, MRS. E, is of legal age, Filipino citizen, single, with residence and postal
address at Unit No. 6 Lapu Lapu Street, Legazpi City, where they may be served with summons
and other court processes;
3. The plaintiff is the owner of a condominium unit located at Unit No. 6, Lapu Lapu Street,
Legazpi City, as shown in the Condominium Certificate of Title No. 56348, attached herein as
“Annex A”;
4. That the plaintiff and the defendant entered a contract of lease for the rental of the aforesaid
condominium unit for P8,500.00 a month as rental to be paid within the first ten (8) days of each
month starting April 1, 2020;
5. That the defendant failed to pay the agreed rental for several months starting January 1, 2021 up
to the present;
6. That on March 13, 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 attached herein as Annex “B”;
7. That 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 failure of the defendant in vacating 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
P15,000.00.
 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 P8,500.00 per month as compensation for the reasonable
1. use of the subject premises until they finally vacate the said premises;
2. To pay the plaintiff the cost of the suit.

City of Legazpi, March 13, 2021.

CAVANI LAW OFFICE

Unit 410, Garrison Tower II
Cabangan, Legazpi City

By:

Atty. T
Counsel of the Plaintiff
Roll of Attorney No. 98765
IBP No. 73256/6-7-13/Legazpi City
PTR No. 82541/18-66-15/Legazpi City
 VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines)

City of Legazpi) S.S.

I, Mr. D, of legal age, after having been duly sworn in accordance with law, dispose and state
that:

1. I am the Plaintiff in the above-stated case;

2. I am caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are true and correct of my personal
knowledge and/or on the basis of copies of documents and records in my possession;
4. I have not commenced other action or proceeding involving the same issues in the Supreme
Court, Court of Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or proceeding is pending in the Supreme
Court, Court of Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has been filed or is pending before
Supreme Court, Court of Appeals, or any other tribunal or agency, I undertake to report that fact
within five (5) days therefrom to this Honorable Court.

Mr. D
Affiant

SUBSCRIBED AND SWORN to before me this 14th of March 2021, at the City of Legazpi,
affiant exhibiting to me her Passport with No. BC1234567 issued on 16 th of April 2019 at the City of
Legazpi.

ATTY. T.
Notary Public
My Commission Expires Dec. 31, 2021
Roll of Attorney No. 98765
IBP No. 73256/6-7-13/Legazpi City
PTR No. 82541/18-66-15/Legazpi City

Doc. No. 43;

Page No. 6;
Book No. IV;
Series of 2021.