Republic of the Philippines

DEPARTMENT OF AGRARIAN REFORM

ADJUDICATION BOARD
Office of the Provincial Adjudicator
WWWWWW, EEEEEEEE

AAAAAAA,
Plaintiff,

-versus- DARAB CASE NO._______________

For: Ejectment, Accounting of Unpaid
Lease Rentals with Damages.

BBBBBBB,
Defendant.
X--------------------------------------------------------------X

C OM P L A IN T

COMES NOW, the plaintiff, thru the undersigned counsel and

unto this Honorable Office, most-respectfully alleges:
1. Plaintiff is of legal age, Filipino and a resident of MMMM, where
orders, notices and other processes of the Honorable Office may
be served upon her;

2. Respondent is of legal age, Filipino and resident of NNN, where

both may be served with summons, orders, notices and other
processes of this Honorable Office;

3. Plaintiff has lawfully acquired absolute ownership of a parcel of

land thru sale from its former owner, ID, which contains an area
of 2,303 square meters, located at MMMMM and eventually
registered said property in her name under TCT NO. T-1111;
Copy of TCT NO. T-1111 is hereto attached and made an integral
part hereof as ANNEX “A”;

4. Unfortunately, however, plaintiff was denied possession of the

contested property as defendants have been occupying the same
and clinging on their claim that they were the tenants of ID,
former owner thereof;

5. In assuring and protecting her ownership thereof, plaintiff had

since demanded payment of leasehold obligations as early as
2009 but defendant deliberately refused to heed such valid
request and which stubborn stance had persisted up to this time
1
 constituting valid ground to cause the outright eviction of the
defendant from occupying the disputed property;

6. Recently, plaintiff further discovered that defendant has

mortgaged the contested parcel of land and conveyed possession
thereof unto a certain WWWW; Copy of the sworn affidavit of
WWWW is hereto attached and made an integral part hereof as
ANNEX “B”;

7. A mediation proceeding was facilitated at the Office of the BARC

Chairman of MMMM but no amicable settlement of dispute was
attained; Copy of the Certification to this effect is hereto
attached and made an integral part hereof as ANNEX “C”;

8. Undeniably, said act of subleasing coupled with the evident

deliberate non-payment of lease rentals are both construed as a
ground for termination of leasehold relationship and eviction of
the defendant from the subject landholding;

9. Plaintiff suffered sleepless nights, mental anguish, fright, serious

anxiety, besmirched reputation, wounded feelings and social
humiliation as a result of the complained unlawful act which
defendant should be made to pay to the plaintiff the sum of One
Hundred Thousand Pesos (Php100,000.00) by way of moral
damages;

10. By way of example or correction for the public good, the

defendant should likewise be made to pay the amount of Fifty
Thousand Pesos (Php50,000.00) as exemplary damages to serve
as deterrent to those who might perpetrate similar illegal acts;

WHEREFORE, in the light of the foregoing, it is most-respectfully

prayed that judgment be rendered in favor of the plaintiff thereby
ordering defendant to immediately vacate the entire landholding being
occupied by the defendant and turn over possession and cultivation
thereof unto the plaintiff. Moreover, it is further pleaded that
accounting of unpaid lease rentals be immediately directed and
defendant be ordered to pay unto the plaintiff all the accumulated
arrearages with interest.
Further, plaintiff pleads for payment of moral and exemplary
damages plus agreed attorney’s fees and cost of litigation.
Other reliefs just and fair under the premises are likewise prayed
for.
RRRR. June 8, 2023.

ATTY. XXX
Counsel for the Plaintiff
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 VERIFICATION AND CERTIFICATION

The undersigned affiant with personal circumstances mentioned

above and after being sworn in accordance with law, hereby deposes
and states:
1. That I am the plaintiff in the above-captioned case;
2. That I have caused the preparation of this complaint, read and
know the contents thereof and that all the allegations stated
therein are true and correct as to my own personal knowledge
or based on authentic records;
3. I further certify that I have not commenced and/or is not
aware of any other action or proceeding involving the same
land or a portion thereof, or issue in any court, tribunal or
quasi-judicial agency, and to the best of my knowledge, no
such action or proceeding pending in any court, tribunal or
quasi-judicial agency, and if I should thereafter learn that the
same or similar action or claim has been filed or is pending, I
shall report that fact within five (5) days therefrom to this
Honorable Court where this complaint is filed.
IN WITNESS WHEREOF, I have hereunto set my hand and affix
my signature this ______day of __________________, 2023 at RRRR.

AAAA
Affiant

SUBSCRIBED AND SWORN to before me this _____ day of

______ 2023 at ___________________________, .

____________________
Notary Public

Doc. No. ______;

Page No. ______;
Book No. ______;
Series of 2023