REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

Vigan City
Branch 10

JUAN TAMAD,
Plaintiff, CIVIL CASE No. 12345
FOR: Unlawful Detainer

-versus-

JUAN SIPAG,
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:

That the plaintiff, JUAN TAMAD, is of legal age, Filipino citizen, single, with
residence and postal address at Brgy. 1 Vigan City, Ilocos Sur;

That the defendant, JUAN SIPAG, is of legal age, Filipino citizen, single, with
residence and postal address at Brgy 1, Vigan City, Ilocos Sur, where they may be served
with summons and other court processes;

The plaintiff is the owner of a land over which an apartment had been constructed
located Brgy 1, Vigan City, Ilocos Sur;

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 February 10, 2020;

The defendant failed to pay the agreed rental for several months starting
December 10, 2020 up to the present;

On February 09, 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”;

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;

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 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.

IN WITNESS WHEREOF, I have hereunto set my hand this 3rd th day of May,
2021 at Vigan City, Ilocos Sur.

PHREXILYN D. PAJARILLO
Roll of Attorney No. 12345
IBP No. 12345/2-5-21
PTR No. 87654/12-22-20

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF ILOCOS SUR )
CITY OF VIGAN )

I, JUAN TAMAD, of legal age, Filipino citizen, single and resident of Brgy. 1, Vigan
City, Ilocos Sur, after having been duly sworn to in accord Nance with law do hereby
depose and say:

That I am the plaintiff in the above-entitled case;

That I have caused the preparation of the foregoing complaint and have read the
allegations contained therein;

The allegations in the said complaint are true and correct of my own knowledge
and authentic records;

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;

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 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;

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 set my hand this 3rd th day of May,
2021 at Vigan City, Ilocos Sur.

JUAN TAMAD

SUBSCRIBED AND SWORN to before me this 3 rd day of May, 2021 , in the City of
Vigan, affiant exhibiting to me his Driver’s License No. 12345 issued by the Land
Transportation Office on April 01, 2020 at the City of Vigan

PHREXILYN D. PAJARILLO
Notary Public
Roll of Attorney No. 12345
IBP No. 12345/2-5-21
PTR No. 87654/12-22-20

Doc. No. ________

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

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