REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Makati
Branch 208

MULTIMIND SOLUTIONS
PHILIPPINES, INC.
Plaintiff,
CIVIL CASE No. 44357
-versus- FOR: Unlawful Detainer

TONI ANGELI COO

Defendant

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and

unto this Honorable Court, most respectfully avers:

1. That the plaintiff, MULTIMIND SOLUTIONS PHILIPPINES, INC., is a

Filipino corporation with the principal place of business at 7 Washington
Loop Britanny Bay Sucat La Posada Muntinlupa, Metro Manila, as hereto
shown in its Articles of Incorporation attached as Annex A, where it may
be served with summons and other court processes;

2. That the defendant, TONI ANGELI COO, is of legal age, Filipino

citizen, single, with residence and postal address at 8471 Trabajo St.,
Barangay Olimpia, Makati City, Metro Manila, where she may be
served with summons and other court processes;

3. Defendant is plaintiffs Corporate Secretary and shareholder as hereto

shown in the corporations General Information Sheet attached as
Annex B;

4. The plaintiff is the owner of a land over which a commercial building

had been constructed located at ___________________ as hereto
shown in the TCT No. ______ attached as Annex C;
5. That on December 29, 2009 plaintiff and defendant entered into a
Contract wherein the plaintiff agreed to lease the third (3 rd) floor of
the aforementioned commercial building to defendant from January 1,
2010 to January 1, 2020, as hereto shown in the Lease Contract
attached as Annex D.

6. The lease of the commercial space is for a consideration of

P50,000.00 a month as rental to be paid within the first (1 st) day of
each month starting January 1, 2010 without any need for demand;

7. The defendant deliberately failed to pay the agreed rental for thirteen
(13) months starting January 1, 2016 up to the present;

8. On March 1, 2016, the plaintiff sent the first Letter of Demand to Pay
arrears in rent, attached here as Annex E, which was received by the
defendant as shown in the registry return receipt hereto attached as
Annex F;

9. On May 1, 2016, the plaintiff sent the second Letter of Demand to Pay
arrears in rent, attached here as Annex G, which was received by
the defendant as shown in the registry return receipt hereto attached as
Annex H;

10. On July 1, 2016, the plaintiff sent the Letter of Demand to Pay arrears
in rent, attached here as Annex I, which was received by the
defendant as shown in the registry return receipt hereto attached as
Annex J;

11. On September 1, 2016, the plaintiff sent the fourth Letter of Demand
to Pay with Notice to Vacate, attached here as Annex K, which was
received by the defendant as shown in the registry return receipt
hereto attached as Annex L;

12. On November 1, 2016, the plaintiff sent a Final Letter of Demand to

Pay with Notice to Vacate, attached here as Annex M, which was
received by the defendant as shown in the registry return receipt
hereto attached as Annex N;

13. Despite these formal letter of demands which were repeated by oral
demands, the defendant deliberately and wilfully refused to pay the
agreed amount of rentals;

14. By reason of failure of the defendant to vacate the premises and to pay
the unpaid rentals, the plaintiff was compelled to file this complaint
engaging the services of counsel in the amount of P10,000.00.
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

unto this Honorable Court that, after hearing, judgment be rendered ordering
the defendant:

1. To vacate the subject premises;

2. To pay the unpaid rentals amounting to six hundred and fifty thousand
pesos (P 650,000.00)
3. To pay the amount of P5,000.00 per month as compensation for the
reasonable use of the subject premises until they finally vacate the said
premises;
4. To pay the plaintiff the cost of the suit.

City of Makati, January 18, 2017.

MANOLO LAW OFFICE

Counsel for the Plaintiff
UNIT 2212, W TOWER
45TH AVE, ZIRCON STREET
BONIFACIO GLOBAL CITY, TAGUIG
METRO MANILA, PHILIPPINES
778-8888; 778-8889; 778-8890

By:

JULIUS C. DIMACULANGAN
Roll of Attorney No. 76682
IBP No. 12345/1-5-12/Manila
PTR No. 87654/12-22-12/Manila
Republic of the Philippines )
City of Makati ) S.S.

CERTIFICATION OF NON-FORUM SHOPPING

I, MULTIMIND SOLUTIONS PHILIPPINES, INC, a Filipino Corporation,

formed under Philippine laws, after having been duly sworn in accordance
with law, depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and/or on the basis of copies
of documents and records in my possession;
4. I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;
5. To the best of my knowledge and belief, no such action or proceeding
is pending in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has
been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

______________________
Affiant

SUBSCRIBED AND SWORN before me this 18th day of January

2017 at Makati City, affiant exhibiting to me its Tax Identification No. 009-
232-530-000 issued on ________________ 20__ at ____ City.

ATTY. MIRIAM DEMAGIBA

NOTARY PUBLIC
My Commission Expires Dec. 31, 2018
Roll of Attorney No. 34567
IBP No. 12345/1-5-00/Manila
PTR No. 87654/12-22-00/Manila

Doc. No. ;
Page No. ;
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Series of 2017.