REPUBLIC OF THE PHILIPPINES NATIONAL

CAPITAL JUDICIAL REGION REGIONAL TRIAL

COURT
Las Piñas city
Branch 1

Rex Leandro
Plaintiff,
Civil Case No. 132125
-versus- For: Breach of Non-Compete clause with
damages

Dwayne Johnson
Defendant.

X---------------------------------------------- X

COMPLAINT

COMES NOW the plaintiff, by the undersigned counsel, and to this

Honorable Court, respectfully alleges:

1. That the plaintiff is of legal age, Filipino citizen and resident of

Blk 6 Lot 6 Bagumbayan, Rizal St., Las pinas city and the
defendant is also of legal age, Filipino citizen and a resident of No.
1 Lumangbayan, Las pinas City where he may be served with
summons;

2. That on or about July 19, 2023, the defendant was caught by our
employee in a bar located in Times, Las Pinas city, Owned by June Mar, one
of the primary competitors of the plaintiff, dancing on top of a stage butt
naked.

3. On July 20, 2023, the defendant was reported by a staff that he was
being persuaded by the defendant to quit the job and to work for
June Mar.

4. Under the contract, the defendant was prohibited from working

as a macho dancer owned by June Mar. There was also a breach
of defendant’s Non-solicitation obligation under the contract.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that judgement be rendered in

favor of the plaintiff and against the defendant, ordering the latter to pay the following sums:

1. 500,000 – as stipulated in the contract;

 2. 10,000 – for and as Attorney’s Fees as well as the costs of suit.

Other reliefs just and equitable in the premises are likewise prayed
for.

August 1, Las Pinas city

Atty.

Verification with certification of Non-Forum Shopping

I, Reax Leandro, petitioner in the above-captioned case, single , of legal age , Filipino, after
having been sworn , in accordance with law, hereby depose and state that :

1. I am the petitioner in the above-captioned case;

2. I have read and understood the contents hereof of this Complaint , and the facts herein
alleged are true and correct of my own knowledge and based on available verifiable
records;

3. I have not commenced any other action or proceeding or any claim , or filed any claim
involving the same issues raised in the above-captioned case, in this Honorable
Supreme Court , in the Court of Appeals , nor the different divisions thereof, nor in any
other court or tribunal or agency and, to the best of my knowledge , no such other
action or claim is pending therein;

IN WITNESS WHEREOF, I HAVE HEREUNTO SET MY HANDS THIS 3RD DAY OF AUGUST 2023

AFFIANT

SUBSCRIBED AND SWORN to before me this 4th day of august 2023.