REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT ___JUDICIAL REGION BRANCH___, MANILA

JUAN DELA CRUZ, Plaintiff, -versusCivil Case No._______ For: Ejectmant JOHN DOE, Defendant.
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COMPLAINT

Plaintiff, by counsel, unto this Honorable Court most respectfully alleges:

1. That the is of age and resident of 123 Acacia Avenue, Diliman, Quezon City; while the defendant is also of age, with residence and post-office address at 1560 Narra Street, Diliman, Quezon City.

2. That the plaintiff is the absolute owner and lessor of that certain building located at 1560 Narra Street, Diliman, Quezon City and now leased and occupied by the defendant.

3. That the defendant leases and occupies the said building under the express obligation of paying a rent of One Hundred Thousand Pesos (PhP 100,000) a month payable in advance within the first five (5) days of each month.

4. That the defendant has not paid the rents for the said building for the months of October, November, December 2011.

5. That the plaintiff has several times demanded of the defendant to vacate the above premises and to pay his back rents, now amounting to Three Hundred Thousand Pesos (PhP 300,000), the last demand for payment having been made on him personally and in writing on 10 January 2012 or more that five days before filing of this complaint. A copy of the demand letter received by the defendant is attached hereto as Annex A.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that, after due hearing, judgement be rendered in favour of the plaintiff: (a) For the restitution of the above-mentioned premises; (b) For the payment of Php 300,000, representing the arrears of rent now overdue, with legal interest from the filing of this complaint, and costs of this suit.

All other reliefs just and equitable under the premises are likewise prayed for.

Quezon City, Philippines, 15 February 2012.

ATTY. MILA MARQUEZ Counsel for Plaintiff Golden Dove Tower, Ortigas Avenue Mandaluyong City PTR No. 1473621; 01/08/2012 IBP No. 123041; 01/08/2012 Roll No. 54321 MCLE Compliance No. 12345; 1/10/2010

REPUBLIC OF THE PHILIPPINES) QUEZON CITY ) S.S. VERIFICATION AND CERTIFICATE I, JUAN DELA CRUZ, of legal age, married, Filipino, with residence ate 123 Acacia Avenue, Diliman, Quezon City, after having sworn to in accordance with law, hereby depose and state: 1. That I am the Plaintiff in the above-entitled case.

2. That I caused the preparation of this complaint, and have read it, and the contents thereof are true and correct of my personal knowledge and as based on the records on hand.

3. That I further certify that I have not commenced any action or filed any claim involving the same issued in any court, tribunal or quasi-judicial agency, and there is no other action or claim pending therein; that if there is any such pending action or claim or similar action or claim pending, I shall immediately report that fact to this Honorable Court, within five (5) days from knowledge thereof. IN WITNESS THEREOF, I hereunto affix my signature this 15th day of February 2012, at Manila, Philippines. JUAN DELA CRUZ Affiant SUBSCRIBED AND SWORN TO before me this 14th day of February 2012, at Manila, Philippines, affiant exhibiting to me his passport with No. XX1234567 issued on 10 January 2012 in Manila. ATTY. ANTONIO DE SILVA Notary Public Doc. No. 72; Page No. 539; Book No. II; Series of 2012

ANNEX A MARQUEZ & MARQUEZ Golden Dove Tower, Ortigas Avenue, Mandaluyong City Telephone no. (02) 789-7843 10 January 2012 Mr. John Doe 1560 Narra Street Diliman, Quezon City Dear Mr. Doe, We write to you on behalf of our client, Juan dela Cruz, the owner of the building located at 1560 Narra Street, Diliman, Quezon City, and which you currently lease for a monthly rental payment of Php 100,000. It appears that as of this writing, you have not paid the rental fee for the property for the months of October, November and December 2011, which amount are already due and demandable. In view of the foregoing, demand is hereby given to you to pay the above-mentioned rental fees within a period of five (5) days from receipt of this letter. If you still fail and / or refuse to settle the same, we will be constrained to resort to legal action to protect the interests of our abovenamed client, in which case exposing you to additional costs and expenses. Hoping that you will give this matter your favourable attention and immediate action.

Truly yours, Atty. Mila Marquez Counsel for Plaintiff

PROMISSORY NOTE Php 500,000

FOR VALUE RECEIVED, I promise to pay without need of demand to order of Alvin Salazar, at his office at Drive 29 Pearl St., Bajada, Manila, the principal amount of Five Hundred Thousand Pesos (P500, 000), Philippine Currency, on or before August 01, 2010. In addition to the foregoing, I promise to pay an interest rate of One percent (1%) every month, commencing from the month of February 2010 until this note is fully paid. In case of default of payment, I agree to pay a penalty equivalent to Three (3%) percent every month based on the total amount due and demandable until fully paid. Should it become necessary to collect this note with the services of a lawyer, I shall pay an amount equivalent to Ten Percent (10%) of the amount claimed in the complaint as attorneys fees, exclusive of costs of litigation and other expenses.

January 02, 2010 at Manila Hotel, Manila, Philippines.

CARLO DE CASTRO