REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

Branch _____
Bataan
MARIA REYES,
Plaintiff,

SCA No. __________

For: Unlawful Detainer
-versus-

PEDRO SANTOS,
Defendant.
x--------------------------x
COMPLANT
COMES NOW< plaintiff through the undersigned counsel, and unto this Honorable Court,
respectfully alleges:

1. That the plaintiff is of age and resident of 3 San Nicolas St. Mariveles, Bataan;
while the defendant is also of age, with residence and post office address at 50 San Nicolas St. Mariviles,
Bataan;
2. That the plaintiff is the absolute owner and lessor of that certain building
located at 5 San Nicolas St. Mariveles, Bataan, and now leased and occupied by the defendant;
3. That the defendant leases and occupies the said building under the express
obligation of paying a rent of P15,000.00 a month, payable in advance within the first five (5) days of
each month;
4. That the defendant has not paid the rents for the said building for the month of
January and February of the current year.
5. That furthermore, the defendant has failed to comply with the conditions of his
lease, namely; The monthly rental shall be fifteen thousand PESOS (P15,000), Philippine Currency, to be
paid by the LESSEE at each and every month, plus one per centum (1%) surcharge per month for the
payment of rentals made after the 5 th day of the month due. It is expressly agreed and understood that
the payment of the rental herein stipulated shall be made without the necessity of express demand and
without delay on any ground whatsoever.
6. That the plaintiff has several time demanded of the defendant to vacate the
above premises and to pay his back rents, now amounting to P30,000, the last demand for payment
having been made on him personally and in writing on March 1, 2012 or more than five days before the
filing of this complaint.

WHEREFORE premises considered, plaintiff respectfully prays from this Honorable Court:
(a) That restitution of the above-mentioned premises be grated to plaintiff; and
(b) For the payment of P60,000, representing the arrears of rent now overdue, with
legal interest from the filing of this complaint, and costs of this suit.

Other relies that may be just and equitable are likewise prayed for.

City of Manila, Philippines, March 7, 2016.

ATTY. JUANICO FRANCISCO

Counsel for Plaintiff
Unit 1, X Building, Recto, Manila
IBP No. 123456; 01/10/10- Manila
PTR No. 1234567; 01/10.10- Manila
Roll No. 12345; 5/05/05
MCLE No. I-001234; 9/09/09
MCLE No. II- 005678; 9/09/090909