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Legal Writing Position Paper For Plaintiff
Legal Writing Position Paper For Plaintiff
Legal Writing Position Paper For Plaintiff
JOHNNY CEE,
Plaintiff, Civil Case No. 24843
For: Ejectment
(Unlawful Detainer)
-versus-
GIGI GIMENEZ,
Defendant,
x-----------------------------------------------------------x
PREFATORY STATEMENT
STATEMENT OF FACTS
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solely for residential purposes, and any breach of this condition can be a
cause for the pre-termination of the contract.
DOCUMENTARY EVIDENCE
Exhibit “C” – Notice of Hearing dated November 10, 2014 addressed to the
defendant
Exhibit “C-1” – Certified copy of Conciliation and Mediation proceedings
conducted by the Lupong Tagapamayapa
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Exhibit “C-2” – Certified copy of Minutes of the Meeting of the Conciliation
and Mediation proceeding conducted by the Lupong
Tagapamayapa
Purpose: To prove that demand was made for defendant to vacate the
premises but due to her deliberate refusal, plaintiff was compelled to
raise the dispute to the Office of the Barangay Captain of Barangay
Sikatuna, Quezon City
ISSUES
From the pleadings submitted by the parties, the following issues are
raised for the resolution of the Honorable Court:
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found thereon, and the lessee fails to comply therewith after fifteen
(15) days in the case of land or five (5) days in the case of buildings.”
In the case at bar, it is established that the defendant is a tenant of the
former owner with Contract of Lease. Plaintiff and defendant agreed that the
latter shall use said premises leased by her solely for residential purpose, and
violation of which shall cause the termination of the contract. Clearly,
defendant violated the tenor of the contract entered into by her with herein
plaintiff, and as such, the right to terminate the contract and eject the lessee
therefrom is conferred upon the plaintiff. However, defendant deliberately
refused to vacate said premises despite several demands by the plaintiff and,
as a result thereof, the latter was compelled to file an ejectment complaint
with the Honorable Court on December 20, 2014.
RONNIL C. ROSILLO
Counsel for Plaintiff
PTR No. 1077517, 1/3/2014, QC
IBP O.R. No. 491316, 1/3/2014, QC
Office Address:
No. 49- E Mahinhin Street,
Bgy. Teachers Village West,
Diliman, Quezon City
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2. That I caused the preparation of the Position Paper and read and
understood the contents thereof;
3. That the allegations contained in the Position Paper are true and
correct to the best of my knowledge and belief;
JOHNNY CEE
Doc. No. 30
Page No. 23 RONNIL C. ROSILLO
Book No. 23 NOTARY PUBLIC
Series of 2001 PTR No. 1077517 1/3/2014, Q.C
IBP O.R No. 491316,
1/3/2014, Q.C
Office Address:
No. 49- E Mahinhin Street,
Bgy. Teachers Village West,
Diliman, Quezon City