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Tuesday, June 5, 2012

Complaint Sample
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Republic of the
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Municipal Trial Court
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Branch 5
Baguio City

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COMES NOW, the plaintiff together with the

undersigned counsel to this most Blog Archive
honorable court, MOST RESPECTFULLY STATES
THAT; June (42)

1.         
The Plaintiff is of legal age, married and a resident
of Puguis, La Trinidad Benguet.
The Defendant is likewise of legal age, married
and temporary residing at Petersville
Subdivision, Baguio City. About Me
2.         
The Plaintiff is the owner of the two-storey house unit
located at the Petersville
Subdivision, Baguio City, and having the residential
address of PV 123 as evidenced ValreD
by pertinent documents like tax declaration and
deed of sale. ( EXHIBIT “A” )
Just a passer-by in this
3.         
The Defendant is the lessee of the house unit that is
owned by the Plaintiff as world. Just another
evidenced by the written contract of lease that both
parties signed. (Exhibit “B”)
dreamer....:)
4.     
The Plaintiff and the Defendant came up with a written
agreement of Lease on June
26, 2007, which they both agreed upon and was duly
signed by the two parties as View my complete profile
shown in their contract of lease. (Exhibit “B”)
5.     
Item No. 16 of the contract which the defendant signed
expressly provides that he will
only be occupying the property for one (1)
year, after which, he will vacate the house
when that term expires. (Exhibit
“B”)
6.         
The contract also provides that the defendant should
also take care of the property
and its premises” with the utmost diligence”.
7.     
On June 28, 2008, the plaintiff, after returning from
Japan, was surprised to discover
that the defendant did not vacate the property
as he expected. Worse, he installed a
“sari-sari store” in the original
building structure of the house unit.
8.     
The plaintiff confronted the defendant about it but the
defendant claimed that it  was a
“DEED OF
SALE” which they signed and not a “CONTRACT OF LEASE” and
therefore, the
defendant is the new owner of the house unit.
9.     
On August 20, 2008, after continuous demands, the
defendant constantly refuses to
vacate the house unit and even invited
relatives to stay with him.
10.  The
defendant willfully and maliciously violated the agreement which they mutually
agreed upon, and which the defendant signed.
 PRAYER

WHEREFORE, premises considered, it is

most respectfully prayed of this Honorable Court that
judgement be rendered in
favor of the plaintiff and that after judgement;

a.      
The defendant shall vacate the house unit owned by the
plaintiff.
b.     
The defendant shall be ordered to pay P 120, 000 for
the Attorney’s Fees.

            Such
other reliefs and remedies under the premises are likewise prayed for.
           
Baguio City,
Philippines, this 28th day of September 2008.

Poging Attorney
Counsel for the Plaintiff
PTR
No. 18909595:1-04-07:B.C.
IBP
No, 693095:1-04-07:B.C.
Roll
No. 42481:5-10-97: Manila
Rm.
4 2/F Baguio Boating Center
180
Burnham Lake, Baguio City

VERIFICATION AND CERTIFICATION

I, Mr. Uzumaki
Naruto, of Legal age, married, Filipino Citizen and a resident of
Puguis, La
Trinidad Benguet, after being sworn according to law, hereby 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.

Uzumaki Naruto
Complainant

In witness thereof, I,
Mr. Poging Attorney, counsel of the plaintiff, have herunto set
my hand this 29th
of September at Baguio City.

Poging Attorney
Counsel for the Plaintiff
PTR
No. 18909595:1-04-07:B.C.
IBP
No, 693095:1-04-07:B.C.
Roll
No. 42481:5-10-97: Manila