REPUBLIC OF THE PHILIPPINES

COURT
City of ___________
Branch _______
Plaintiff,
CIVIL CASE No. 9876 -
versus- FOR: Unlawful Detainer

Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel

and unto this Honorable Court, most respectfully avers:

1. That the plaintiff, ___________ , is of legal age, Filipino citizen, single,

with residence and postal address _______________;
2. That the defendant, _____________, is of legal age, Filipino citizen,
single, with residence and postal address at ____________________,
where they may be served with summons and other court processes;
3. The plaintiff is the owner of a land over which an apartment had been
constructed located_________________ ;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant
the aforesaid apartment for a consideration of _______________ a
month as rental to be paid within the first ten (10) days of each month
starting ________________;
5. The defendant failed to pay the agreed rental for several months
starting _____________ up to the present;
6. On___________, the plaintiff sent a letter of demand to vacate the
apartment which was received by the defendant as shown in the
registry return receipt hereto attached as Annex “A”;
7. Despite said letter of demand which was repeated by oral demands,
the defendant failed and still refused to pay the agreed amount of
rentals and to vacated the apartment;
8. 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 _______________.
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 amount of ________ per month as compensation for the
reasonable use of the subject premises until they finally vacate the said
premises;
3. To pay the plaintiff the cost of the suit.
City of___________, (date) .

AAC and ASSOCIATES LAW FIRM

Cebu City Tel No. 4952328
Email Address: aac_law@gmail.com
By:

ANA HANNESA S. APELLIDO

Notarial Commission No.: 123
Until December 31, 2018
Roll of Attorney No. 101493
IBP Lifetime No. 1014
Chapter (Cebu City)
MCLE No. 1015
Capitol Site, Cebu City
 VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of _________ ) S.S.

I, _____________ , of legal age, Filipino citizen, single and

resident __________________ , after having been duly sworn to in
accordance with law do hereby depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and
have read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or
proceeding involving the same issues in any court, tribunal or quasi-
judicial agency and, to the best of my knowledge, no such other action
or claim is pending therein;
5. That if I should learn thereafter that a similar action or proceeding has
been filed or is pending, I hereby undertake to report that fact within
five (5) days therefrom to the court or agency where the original
pleading and sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular No.
04-94 of the Honorable Supreme Court.
 IN WITNESS WHEREOF, I have hereunto affixed my signature
this _____________ , in the City of ____________ .

AFFIANGT

SUBSCRIBED AND SWORN to before me this _______ day

of_______________ , in the City of ____________, affiant exhibiting
to me his ____________ issued by the ___________ on
_____________ at the City of _____________.

ANA HANNESA S. APELLIDO

Notarial Commission No.: 123
Until December 31, 2018
Roll of Attorney No. 101493
IBP Lifetime No. 1014
Chapter (Cebu City)
MCLE No. 1015
Capitol Site, Cebu City