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Republic of the Philippines

13th MUNICIPAL CIRCUIT TRIAL COURT
Second Judicial Region
San Manuel-Aurora
Province of Isabela

Mr. A and Mrs. A1,

Plaintiff
- Versus– Civil Case No.
Mr. B and Mrs. B1 For Unlawful Detainer
Defendant
x--------------------------------------------------x

COMPLAINT

COMES NOW, the Plaintiff, by the undersigned counsel and unto

this Honorable Court, most respectfully states:

The Parties

1. That plaintiff A and A1 are of legal age, Filipinos, spouses, with

residence located at Purok 5, District no. 4, San Manuel,
Isabela;
2. That defendant B and B1 are of legal age, Filipinos, spouses,
with residence located at Purok 3, District no. 3, San Manuel,
Isabela.

Causes of Action

3. That Plaintiff-A is the lessor of a certain property pursuant to a

lease contract attached as Annex A executed on December 25,
2017, by which the subject property is a building erected on
TCT-555, copy of which is attached as Annex B;
 4. That herein Defendant-B was the lessee of the lease contract
Page 2 of 4
referred in the preceding paragraph.
5. That the lease contract referred in the preceding paragraphs
expired on January 1, 2020 by which the lessee should have
vacated the subject property pursuant to the lease contract.
6. That on January 02, 2020 and on February 03, 2020, demands
were given and made known to Defendant-B. Demand letters
are attached as Annex C.1 and C.2
7. That Defendant-B refused to vacate the premises despite
repeated demands. Joint Judicial affidavit of X and Y is attached
herewith as Annex D to testify defendant’s continuous illegal
possession of the subject property of the contract of lease.
8. That due to refusal to vacate for already a period of 6 months,
additional charges was incurred and not paid by the defendants.
Computation of charges as of July 1, 2020 is attached as Annex
E.

Relief

ACCORDINGLY, plaintiff asks this Honorable Court that

judgement be rendered in accordance with the following reliefs:

1. That Defendant-B vacates the premises immediately.

2. That defendant pay the unpaid liabilities pursuant to Annex E
without prejudice to additional charges up to the time the
defendant vacates the premises.

Other reliefs just and equitable are also prayed for.

01 July 2020. San Manuel, Isabela

ATTY. WALLY CACULITAN ARANAS, CPA

Counsel for Plaintiff
Purok 5, District no. 4, San Manuel, Isabela
Roll No. 12345
PTR No. 8882221 01/10/2020 Isabela
IBP No. 690120 01/05/2020 Isabela
MCLE Compliance III-0008269-02/29/19
 Page 3 of 4

VERIFICATION / CERTIFICATION

We, Mr. A and Mrs. A1, state under oath that I/we have read the
above complaint and the allegations in it are true and correct based on
my/our personal knowledge and/or based on authentic record. We also
certify under oath (a) that we have not previously filed any action
involving the same issues in any court, tribunal or quasi-judicial agency;
(b) that to the best of my/our knowledge, no such action is pending in
any of them; and (c) if I/we should learn of the filing of such action, I/we
shall report it to the court within five days from notice.

San Manuel, Isabela. July 1, 2020.

Affiants:

         ____________________________       _____________________________
     Mr.  A                    Mrs. A1
     

Witnesses: (1) X, single, of legal age (2) Y, single, of legal age

Judicial affidavits attached as mentioned above.

JURAT

Republic of the Philippines)

Municipality of San Manuel
Province of Isabela ) s.s.
 Page 4 of 4

SUBSCRIBED AND SWORN to before me, NOTARY PUBLIC of and

in the Province of Isabela this 1st day of July 2020 at District no. 2, San
Manuel, Isabela. Affiants as well as the witnesses exhibited to me their
respective proof of identity, to wit:

Name ID Type/ID No. ID Expiration Date

A PRC ID/098678 December 31, 2020
A1 PRC ID/098676 October 31, 2020
X PRC ID/098674 August 31, 2020
Y PRC ID/098673 July 31, 2020

I certify that I personally examined the affiants as well as

witnesses and I am satisfied that they voluntarily executed and
understood their affidavits.

This petition consists of 4 pages including the page where this

notarial act is written.

ATTY. JEFF EDILEE LAURETA CORPUZ

NOTARY PUBLIC
Of and in the Province of Isabela
District no. 2, San Manuel, Isabela
Roll No. 13344
PTR No. 8882001 01/10/2020 Isabela
IBP No. 492120 01/05/2020 Isabela
MCLE Compliance III-0001169-02/29/19

Doc. No.: 65;

Page No.: 15;
Book No.: LXIX;
Series of 2020
Annex A
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LEASE CONTRACT

KNOW ALL MEN BY THESE PRESENTS:

I , A, m al e, of legal age, married to A1, with postal address at Purok 5, District No. 4, San
Manuel, Isabela hereinafter known as the LESSOR, and B, male, of legal age, married to B1, with postal
address at Purok 3, District no. 3, San Manuel, Isabela, hereinafter known as the LESSEE, agreed:

1. That the LESSOR is the owner/possessor of a real property consisting of a one-story commercial
building over a land described as follows:
a. The building is a concrete studio-type building, fully furnished, named as Building Ni A,
primarily used for commercial purposes, and built on 2017.
b. The building is erected on a parcel of land covered by TCT-555 with an area of 500 square
meters located at Purok 5, District No. 4, San Manuel, Isabela, registered under the name of the
LESSOR.

2. That the lessor will grant temporary possession of the property mentioned in the preceding item in the
form of lease for a period of two (2) years from occupancy, non-extendible to the LESSEE.
Occupancy will start on January 01, 2018.

3. That the LESSEE agreed to pay according to the following terms:

A. One month advance payment: Php 20,000 (Twenty Thousand Pesos)

B. Monthly Rental: Php 20,000 (Twenty Thousand Pesos)
C. Due Date/Payment Date (1): Item A - prior occupancy
D. Due Date/Payment Date (2): Item B – last day of the month
E. Other terms & conditions:  Interest on failure to pay on the date of payment at 10% per
annum based on 360-day period compounded annually on
the actual number of days. Demand not required for the
accrual of interest for any unpaid payment.
 Improvement on the property allowed subject to the
approval of the lessor.
 Maintenance cost to be shouldered by the LESSEE.
 Failure to vacate the premises at the end of the lease
contract is subject to additional charge of P20,000 per
month pro-rated based on number of days with interest of
10% per annum based on 360-day period compounded
annually based on the actual number of days. Demand not
required for the accrual of interest for any unpaid payment.
 
The parties have hereunto set their hands, this 25th day of December 2017 at District No. 2, San Manuel,
Isabela, Philippines.

         ____________________________       _____________________________
       A, LESSOR                       B, LESSEE
WITH SPOUSE CONSENT:

____________________________       _____________________________ Page 2 of 2

      A1                      B1

 IN THE PRESENCE OF:

         ___________________________________________      

X, single, of legal age, Witness 1, resident of District 4, San Manuel Isabela  

________________________________________
Y, single, of legal age, Witness 2, resident of District 4, San Manuel Isabela 

ACKNOWLEDGEMENT

Republic of the Philippines)

Municipality of San Manuel
Province of Isabela) S.S

BEFORE ME, personally appeared:

Name ID Type/ID No. ID Expiration Date

A PRC ID/098678 December 31, 2020
B PRC ID/099867 November 30, 2020
A1 PRC ID/098676 October 31, 2020
B1 PRC ID/098675 September 30, 2020
X PRC ID/098674 August 31, 2020
Y PRC ID/098673 July 31, 2020
Known to me and known to be the same persons who executed the foregoing instrument containing 2 pages
including the page where this notarial act is written and acknowledged to me that the same is their free and
voluntary act and deed.

WITNESS MY HAND AND SEAL, 25th day of December 2017 at District No. 2, San Manuel, Isabela,
Philippines.

  ATTY. JEFF EDILEE LAURETA CORPUZ

                          NOTARY PUBLIC
Of and in the Province of Isabela
District no. 2, San Manuel, Isabela
Roll No. 13344
PTR No. 8882001 01/10/2020 Isabela
IBP No. 492120 01/05/2020 Isabela
MCLE Compliance III-0001169-02/29/19

Doc. No. 10;

Page No. 10;
Book No. 5;
Series of 2017.
Annex B.1

Mr. B, Lessee
Purok 3, District no.3, San Manuel
Isabela, Philippines
January 02, 2020

Dear Mr. B:

Greetings!
 This is to remind you about you’re obligations pursuant to the lease contract you have signed with me on
December 25, 2017. Said contract ended last January 01, 2020, hence, you’re right to stay and possess the subject
property has already ended.

Thus, we are sending you this DEMAND LETTER for you to vacate the premises. You are given 30 days
from today on which to leave the premises subject to additional charges pursuant to the contract. You are advised to
coordinate with me for any remaining unpaid liabilities. You’re failure to vacate the premises shall leave us with no
other recourse but to file the necessary cases against you.

This letter does not constitute exhaustive statement of our position nor a waiver of the rights and remedies
in this and/or any related matter.

You’re prompt action on the matter is demanded.

Respectfully Yours,

Mr. A, Lessor
Purok 5, District No. 4, San Manuel, Isabela
Annex B.2

Mr. B, Lessee
Purok 3, District no.3, San Manuel
Isabela, Philippines
February 03, 2020

Dear Mr. B:

Greetings!

This is to demand you to vacate the premises pursuant to the lease contract you have signed with me on
December 25, 2017. Said contract ended last January 01, 2020, hence, you’re right to stay and possess the subject
property has already ended. Further, the 30 days grace period given to you already ended.

Thus, we are sending you this FINAL DEMAND LETTER for you to vacate the premises immediately.
You’re failure to vacate the premises shall leave us with no other recourse but to file the necessary cases against.

Also, having been unlawfully staying in the premises despite demand to vacate, you incurred the following
pursuant to our lease contract. You are demanded to pay either personally or thru gcash number 0995-990-9589.

Particulars Amount
Rent for January 2020 P20,000.00
Interest of unpaid rental for January 2020 due on January 31, 2020 up to February 03, 2020 (3
days)
(20,000 x 10% x 3/360) = P 8.3333 16.67
Total P20, 016.67

This letter does not constitute exhaustive statement of our position nor is it any waiver of the rights and
remedies in this and/or any related matter.

You’re prompt action on the matter is demanded.

Respectfully Yours,

Mr. A, Lessor
Purok 5, District No. 4, San Manuel, Isabela
Annex C
Page 1 of 2

Republic of the Philippines)

Municipality of San Manuel
Province of Isabela ) s.s.

JOINT JUDICIAL AFFIDAVIT

 

We, X, male, of legal age, Filipino, single and a resident of District

4, San Manuel Isabela, hereinafter known as Affiant 1, and Y, male, of
legal age, Filipino, single and resident of District 4, San Manuel
Isabela, hereinafter known as Affiant 2 do hereby state under oath:

1. That we attest, to the best of our own personal knowledge, that

Mr. B, up to this date, continuously stays in the premises of Mr. A
referred as follows:

a) A concrete studio-type building, fully furnished, named as

Building Ni A, primarily used for commercial purposes, and
built on 2017.
b) Erected on a parcel of land covered by TCT-555 with an area
of 500 square meters located at Purok 5, District No. 4, San
Manuel, Isabela, registered under the name of Mr. A

2. That it is known to us that the possession of Mr. B of the above

mentioned property exceeded the period covered by the lease
contract between Mr. A and Mr. B which ended on January 01,
2020.

3. Nothing follows.

IN WITNESS WHEREOF, we have hereunto affixed our signatures this

1st day of July, 2020 at San Manuel, Isabela.
 

___________________________________________      
X, Affiant 1 

________________________________________
Y, Affiant 2 

 
 Page 2 of 2

JURAT

Republic of the Philippines)

Municipality of San Manuel
Province of Isabela ) s.s.

SUBSCRIBED AND SWORN to before me, NOTARY PUBLIC of and

in the Province of Isabela this 1st day of July 2020 at District no. 2, San
Manuel, Isabela. Affiants exhibited to me their respective proof of
identity, to wit:

Name ID Type/ID No. ID Expiration Date

X PRC ID/098674 August 31, 2020
Y PRC ID/098673 July 31, 2020

I certify that I personally examined the affiants and I am satisfied

that they voluntarily executed and understood their affidavits.

This affidavit consists of 2 pages including the page where this

notarial act is written.

ATTY. JEFF EDILEE LAURETA CORPUZ

NOTARY PUBLIC
Of and in the Province of Isabela
District no. 2, San Manuel, Isabela
Roll No. 13344
PTR No. 8882001 01/10/2020 Isabela
IBP No. 492120 01/05/2020 Isabela
MCLE Compliance III-0001169-02/29/19

Doc. No.: 70;

Page No.: 16;
Book No.: LXIX;
Series of 2020
Annex D Page 1 of 2

Republic of the Philippines)

Municipality of San Manuel
Province of Isabela ) s.s.

STATEMENT OF ACCOUNT OF THE UNPAID LEASE LIABILITIES

OF MR. B PURSUANT TO HIS LEASE CONTRACT WITH MR. A

Principal Total
2020, January 20,000.00
2020, February 20,000.00
2020, March 20,000.00
2020, April 20,000.00
2020, May 20,000.00 120,000.0
2020, June 20,000.00 0
Interest
Rat
From Up to Days Principal e Amount
Wednesday, 1 July 152.0
Friday, 31 January 2020 2020 0 20,000.00 844.44
Saturday, 29 February Wednesday, 1 July 123.0
2020 2020 0 20,000.00 683.33
Wednesday, 1 July
Tuesday, 31 March 2020 2020 92.00 20,000.00 10 511.11
Wednesday, 1 July %
Thursday, 30 April 2020 2020 62.00 20,000.00 344.44
Wednesday, 1 July
Sunday, 31 May 2020 2020 31.00 20,000.00 172.22
Wednesday, 1 July
Tuesday, 30 June 2020 2020 1.00 20,000.00 5.56 2,561.11
122,561.1
Total Unpaid Principal and Interest from January 1 2020 to July 01, 2020 1
 

IN WITNESS WHEREOF, I have hereunto prepared this and affixed my

signature this 1st day of July, 2020 at San Manuel, Isabela.

________________________________________
A
JURAT

Republic of the Philippines)

Municipality of San Manuel
Province of Isabela ) s.s.
 SUBSCRIBED AND SWORN to before me, NOTARY PUBLIC of and
in the Province of Isabela this 1st day of July 2020 at District no. 2, San
Manuel, Isabela. Affiant exhibited to me their respective proof of
identity, to wit: Page 2 of 2

Name ID Type/ID No. ID Expiration Date

A PRC ID/098678 December 31, 2020

I certify that I personally examined the affiant and I am satisfied

that he voluntarily executed and understood his affidavit.

This affidavit consists of 2 pages including the page where this

notarial act is written.

ATTY. JEFF EDILEE LAURETA CORPUZ

NOTARY PUBLIC
Of and in the Province of Isabela
District no. 2, San Manuel, Isabela
Roll No. 13344
PTR No. 8882001 01/10/2020 Isabela
IBP No. 492120 01/05/2020 Isabela
MCLE Compliance III-0001169-02/29/19

Doc. No.: 72;

Page No.: 16;
Book No.: LXIX;
Series of 2020