Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

12th Judicial Region
Manila

XYZ, CIVIL CASE No. _________

Plaintiff,

-versus- -for-

ABC, UNLAWFUL DETAINER

Defendant,
x- - - - - - - - - - - - - - - - - x

COMPLAINT

PLAINTIFF thru counsel, to this Honorable Court, respectfully avers:

1. That he is Filipino, of legal age, married and residing at 123 Mabuhay

St., Bagyo City where he may be served with summons and
processed by this Honorable Court;

2. That defendant is also Filipino, of legal age, married and residing at

456 Tahimik St.,Bagyo City where he may be served with summons
and processes by this Honorable Court ;

3. That Plaintiff is an owner of a three-door commercial building situated

at corner Mabuhay and Tahimik Sts., Bagyo City covered by TCT No.
T-67891;

4. That on January 15, 2019, Plaintiff and Defendant entered into a

Contract of Lease over one door of the commercial building for a
period of two (2) years starting July 1, 2019 to June 30, 2021; copy of
the Contract of Lease is herein attached as Annex “A”;

5. That the Contract was not renewed by the parties;

6. That defendant continued to occupy the leased premises despite
verbal demands;

7. That a formal demand letter was sent to the defendant on November

15, 2021and was received by him on November 16, 2021 but still
demand, fell on deaf ears; Copy of the demand letter is herein
attached as Annex “B”’

8. That Plaintiff was left with no recourse but to file this suit;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that this

Honorable Court will;

1. Order defendant to vacate the leased premises;

2. Order defendant to pay rental fee for the period of occupation until he
demands the leases premises;

3. Such other reliefs just and equitable.

Manila
June 30, 2022

JUAN DELA CRUZ

Counsel for the Plaintiff
Room 2, 3rd Floor, Mataas Bldg,
Pine and Cone St., Bagyo City
PTR No. 1234567 ; 1-2-2022
IBP No. 2345678; 1-2-2-2022
BIR TIN: 123-456-789-000
MCLE Compliance No. VIII-0234
Issued on January 5, 2022
 VERIFICATION AND CERTIFICATION OF
NON-FORUM SHOPPING

I, XYZ, Filipino, of legal age, married and residing at 123 Mabuhay

St., Bagyo City, Philippineas after having been duly sworn to in accordance
with law, hereby depose and say:

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

2. That I caused for the preparation of the said complaint;

3. That I read the contents thereof to be true and correct based on

my own personal knowledge and authentic documents;

4. That this filing is not filed to harass, cause unnecessary delay, or

needlessly increase the cost of litigation;

5. That the factual allegations therein have evidentiary support or; if

specifically so identified, will likewise have evidentiary support
after a reasonable opportunity for discovery;

6. That I have not commenced any other action involving the same
issues in any court, tribunal or quasi-judicial agency and to the
best of my knowledge, no such other action is pending therein;

7. That I bind myself to inform this Honorable Court within five (5)
calendar days from knowledge that a similar action has been filed
in any court, tribunal or quasi-judicial agency;

FURTHER AFFIANT SAYETH NON.

Bagyo City Manila
June 30, 2022.

XYZ
Affiant
 SUBSCRIBED AND SWORN to before me this 30th day of
June, 2022 at Bagyo City, Philippines, affiant exhibited to me his LTO
Professional Driver’s License No. L-01-98765432.

JUAN DELA CRUZ

Doc. No. _____; Notary Public

Page No. _____; Until December 31, 2022

Book No. _____; Address:
Series of 2022. PTR No. ____________

IBP No. ______________