REPUBLIC OF THE PHILIPPINES

REGION V
REGIONAL TRIAL COURT
Naga City
Branch __

MR. ___,
Plaintiff,

-versus- CIVIL CASE NO. ___

For: Ejectment

MR. ___,
Defendant,

x--------------------------------------------x

COMPLAINT

COMES NOW, the plaintiff, and unto this Honorable Court, most respectfully avers:

1. That plaintiff is of legal age, Filipino citizen, with postal address at ______ ;
2. The defendant ___, of legal age, Filipino citizen, with postal address at _____, where
they may be served with summons and other process by this Honorable Court;
3. That the subject lot/premises was originally owned by A, B, C, and D as evidenced by
their Transfer Certificate of Title Nos. PT-12345 AND PT-67890 under their names. Copy
of Transfer Certificate of Title Nos. Pt-12345 and 67890 are hereto attached as Annexes
“A” and ”B” hereof;
4. That the defendant has been occupying the said premises at ________ for more than
ten (10) years by mere tolerance of the original registered owners;
5. That on March __, 2013, one of the registered owners, D, sold his one-third (1/3) share
over the said parcel of land to the plaintiff, as evidenced by the Deed of Absolute Sale
which is hereto attached as Annex “C” hereof;
6. That as the new owner, plaintiff sent a demand letter to the defendants demanding
from the latter to vacate the premises and to pay a reasonable compensation for the
use of the said premises in the amount of P10,000.00 per month. Copy of the demand
letter personally served to the defendants is hereto attached as Annex “D” hereof;
7. That despite repeated demands orally and in writing, defendants refused and
continuously failing to vacate the said premises and pay the amount of P10,000.00 as
compensation for the reasonable use of the subject premises to the damage and
prejudice of herein plaintiff;
8. That as a result of the unwarranted and unjustifiable refusal of the defendants to vacate
the aforesaid premises/parcel of land and to pay reasonable compensation for the use
of the same, plaintiff suffered sleepless nights, serious anxiety in which he should be
 awarded the amount of P100,000.00 as moral damages, and to set an example to the
public plaintiff should be awarded exemplary damages in the amount of P100,000.00

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court
that, after hearing, judgment be rendered as follows:
1. Ordering the defendants, and all persons claiming right under them to vacate the
subject premises/portion of the lot;
2. Ordering the defendants to pay the amount of P10,000.00 per month as compensation
for the reasonable use of the subject portion of the lot/premises until they finally vacate
the said lot/premises;
3. Ordering the defendants to pay the plaintiff the amount of P100,000.00 as moral
damages, and P100,000.00 as exemplary damages;
4. Ordering the defendants to pay the cost of suit.

Such other relief as may be deemed just and equitable under the premises are likewise
prayed for.

Naga City, March __, 2022.

______ LAW OFFICE

Counsel for the Plaintiff
[Address line 1]
[Address line 2]

By:
[NAME]
IBP Lifetime No. 12345
PTR No. 67890
Roll No. 09876
MCLE Exemption No. 54321
 REPUBLIC OF THE PHILIPPINES
REGION V
REGIONAL TRIAL COURT
Naga City
Branch __

MR. ___,
Plaintiff,

-versus- CIVIL CASE NO. ___

For: Ejectment

MR. ___,
Defendant,

x--------------------------------------------x

REPLY

COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable
Court, most avers:
1. That the plaintiff ADMITS the allegations in paragraphs 1 and 3 of the Answer.
2. That plaintiff specifically deny the allegations in paragraphs 2, 4, 5, 6 of the Answer as
the truth of the matter is that there was no payment made by the said defendant as per
admission in the letter he executed, and the promissory attached to the defendant’s
Answer is a forgery since at the time it was allegedly executed he was in Singapore
having a business meeting with my clients.

WHEREFORE, plaintiff prays for judgment.

1. Ordering the defendant all his monetary claims are stated in his complaint;
2. Cost of suit.

Other relief and remedies as may be deemed just and equitable under the premises are
likewise prayed for.

Naga City, March __, 2022

______ LAW OFFICE

Counsel for the Plaintiff
[Address line 1]
[Address line 2]

By:
[NAME]
 IBP Lifetime No. 12345
PTR No. 67890
Roll No. 09876
MCLE Exemption No. 54321