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April 1, 2018

MR. JUN MIRANDA


No. 9 West Aguila
Green Cross Subdivision, Quezon City

Dear Mr. Miranda,

Based on the authority of our client MR. IAN ALBA, owner of the house
and lot located at No. 9 West Aguila, Green Cross Subdivision, Quezon
City.

You are informed that you have failed to pay your rental for SIX (6)
MONTHS, which have now amounted to THREE HUNDRED
THOUSAND PESOS (Php 300, 000.00).

We are reminding you that our client has sent you a number of demand
letters asking you to pay your rentals and to vacate the premises. However,
the same letters have been left unanswered.

Let it be known then, that this letter is our client’s FINAL DEMAND for
you to PAY YOUR ACCOUNT within FIVE (5) DAYS from receipt and to
VACATE THE premises within FIFTEEN (15) DAYS from receipt of this
notice. Otherwise, you left our client with no choice but to commence suit to
protect his interests.

Respectfully yours,

ATTY. JED SALVIO PARACHA


Bankers Villages VI, Dungon B Jaro Iloilo
Email Add: jed_paracha@yahoo.com
Mobile No. 09073909000
REPUBLIC OF THE PHILIPPIES
NATIONAL CAPITAL REGION
MUNICIPAL TRIAL COURT
CITY OF QUEZON

IAN ALBA,
Plaintiff,
Civil Case No. 6589
- versus - For: Ejectment

JUN MIRANDA,
Defendant.
x ------------------ x

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, single and currently resides at


23 Breech St., Bacolod City; Defendant is a Filipino, of legal age, single and
current resident of No. 9 West Aguila, Green Cross Subdivision, Quezon
City, where he may be served with summons and other pertinent processes.

2. Plaintiff owns that property located at No. 9 West Aguila, Green


Cross Subdivision, Quezon City which it leased to defendant for a term of
two years starting on April 1, 2017, at a monthly rate of P 50,000.

3. Defendant, however, has not paid his rent for six (6) months from
October 1, 2017 to March 30, 2018.

4. Despite demand duly made and received, defendant has refused to


vacate the premises and continues to occupy the property without plaintiff’s
consent.

5. Defendant’s act of dispossession has caused plaintiff to suffer


material injury. Defendant’s continued occupation of the premises has also
forced plaintiff to sue and to incur legal expenses amounting to Fifty
Thousand Pesos (P50, 000.00).

PRAYER

WHEREFORE, plaintiff respectfully prays for judgment in its favor


by ordering defendant to vacate the property and peacefully turn over
possession to plaintiff and for defendant to pay plaintiff the amount of Three
Hundred Thousand Pesos (P 300,000) representing rentals of the house and
lot for six (6) months and Fifty Thousand Pesos (P50,000.00) for Attorney’s
fees.

Other just and equitable reliefs are also prayed for.

Respectfully submitted.

City of Quezon, Philippines April 3, 2018.

ATTY. JED SALVIO PARACHA


Bankers Villages VI, Dungon B Jaro Iloilo
Email Add: jed_paracha@yahoo.com
Mobile No. 09073909000

REPUBLIC OF THE PHILIPPINES}


C I T Y O F QUEZON } S.s.
x==========================x

VERIFICATION AND CERTIFICATION OF NON-FORUM


SHOPPING

I, IAN ALBA, of legal age, 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.

IAN ALBA
Affiant

SUBSCRIBED AND SWORN TO before me on this 3rd day of April


2018, affiant exhibiting before me his Driver’s License no. 324574 issued on
January 20, 2018 in Quezon City.

ATTY. JED SALVIO PARACHA


Bankers Villages VI, Dungon B Jaro Iloilo
Email Add: jed_paracha@yahoo.com
Mobile No. 09073909000