Republic of the Philippines

MUNICIPAL TRIAL COURT

Sorsogon City

Patricia Jimenez,
Plaintiff
Civil Case No. 55121
For: Unlawful Detainer

Cleo Annalise Rodriguez

Respondent
X------------------------------X

COMPLAINT

Patricia Jimenez, by counsel unto this Honorable Court, most respectfully

allege the following:

1. Patricia Jimenez (PATRICIA for brevity) of legal age, Filipino, married,

with residence and postal address at Unit 1 Matrix Townhouse, La Playa
Subdivision, Bonot, Sorsogon City.

2. Plaintiff is represented by ABCDE Law Office, with business address at

Mapuya Building, Bonot, Sorsogon City where the plaintiff may be served
notices and other court processes.

3. Cleo Annalise Rodriguez (CLEO for brevity) is of legal age, single with
residence and postal address at Unit 3 Matrix Townhouse, La Playa
Subdivision, Bonot, Sorsogon City.

4. Patricia is the absolute owner of the property (see Exhibit A) used by

Cleo as her principal residence after the termination of the lease contract of
sixteen months while only six months have lapsed.

5. The lease contract (Exhibit B) executed by Patricia and Cleo dated May
20, 2020 agreed that the monthly rental is 25,000 pesos.
6. One of the stipulations in the contract states that failure of Cleo to pay for
two months would incur an additional 2% interest of the total unpaid rent.

7. In another stipulation, failure of Cleo to pay for three months would allow
Patricia to terminate the contract at will.

8. On July 20,2020, Patricia encashed the check for the month of June, but
was dishonored (Exhibit C). Patricia then informed Cleo of the dishonored
check, while the later explained that she could not pay and would do so the
next month. Patricia relented.

9. On September 22, 2020, Patricia tried to encash a check worth 75,000

pesos but was once again dishonored due to insufficiency of funds (Exhibit
D).

10. When Patricia was not able to contact Cleo, she reported the incident at
the Barangay Bonot Barangay Hall (See Exhibit E) where Patricia demanded
the payment of 75,000 pesos in cash. Cleo failed to do so.

11. On September 25, 2020. with counsel asked Cleo to vacate the leased
place by virtue of the stipulation in their leased contract, and demanded the
payment of the unpaid rentals with interest.

12. Up to the present, Cleo refuses to vacate the premises and have only paid
rentals for two months without any of the stipulated 2% interest.

13. Cleo, thus is unlawfully possessing the property while depriving Patricia
for her earnings.

14. Before filing this complaint, this dispute has been referred to the
Lupong Tagapamayapa of Bgy. Bonot but both parties failed to come to any
agreement.
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that after due notice and hearing, judgment be rendered in
favor of Patricia:

1. For the restitution of the abovementioned apartment;

2. For the payment of TWENTY THOUSAND PESOS (P100,000.00),
Philippine currency, representing the arrears of rent now overdue and the 2%
interest stipulated in the lease contract;
3. To pay the cost of the suit amounting to TWO HUNDRED
THOUSAND PESOS.

Other reliefs just and equitable under the premises are likewise prayed for.
Sorsogon City, Philippines, March 11, 2021.

ATTY. ABDCE
Counsel for Plaintiff
ABCDE Law Office
Mapuya Building, Bonot, Sorsogon City

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

Republic of the Philippines

(City of Cavite ) S.S.

I, Patricia Jimenez, of legal age, after having been duly sworn in accordance
with law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I 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 any other action or proceeding involving the same
issues in the Supreme Court, the 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, the 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 the Supreme Court, the Court of Appeals, or any
other tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this Honorable Court.

Sorsogon City, Philippines, March 11, 2021

________________
Patricia Jimenez

SUBSCRIBED AND SWORN to before me this 31st day of

March 2016 at Cavite City, Philippines affiant exhibiting to me her
government issued passport with Passport No. XXX-XXX-XXX issued in
DFA Legazpi City 2020.

NOTARY PUBLIC for SORSOGON CITY

Commission Serial No.______
Until December 31, 2021
Roll of Attorney_______
IBP No.________
PTR No._______
Doc No___
Page No___
Book No___
Series of 2021.