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25th September 2012 Complaint for Unlawful Detainer


Sample

REPUBLIC OF THE PHILIPPINES


METROPOLITAN TRIAL COURT
City of Manila
Branch 1

KRUL ACOSTA,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Unlawful Detainer

MEGAN VITUG,
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1. That the plaintiff, KRUL ACOSTA, is of legal age, Filipino citizen, single, with
residence and postal address at 123 Benitez Street, Manila;
2. That the defendant, MEGAN VITUG, is of legal age, Filipino citizen, single, with
residence and postal address at 456 Modesto Street, Manila, where they may be
served with summons and other court processes;

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3. The plaintiff is the owner of a land over which an apartment had been constructed
located 654 San Pedro Street, Manila;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid
apartment for a consideration of P5,000.00 a month as rental to be paid within the
first ten (10) days of each month starting November 3, 2011;
5. The defendant failed to pay the agreed rental for several months starting February
19, 2012 up to the present;
6. On May 3, 2012, 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 P10,000.00.
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 P5,000.00 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 Manila, September 24, 2012.

REYES, TOLENTINO AND CRUZ LAW OFFICE


Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Manila

By:
Louise Reyes
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )


City of Manila ) S.S.

I, KRUL ACOSTA, of legal age, Filipino citizen, single and resident of 123 Benitez
Street, Manila, after having been duly sworn to in accord Nance with law do hereby

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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 24th of
September 2012, in the City of Manila.

KRUL ACOSTA

SUBSCRIBED AND SWORN to before me this _______ day of September, 2012,


in the City of Manila, affiant exhibiting to me his Driver’s License No. 12345 issued by
the Land Transportation Office on April 8, 2012 at the City of Manila.

ATTY. NO CASE
Notary Public
My Commission Expires Dec. 31, 2012
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

Doc. No. ________


Page No. _______
Book No. _______
Series of 2012.

Posted 25th September 2012 by MRC

Labels: Forms in Civil Action, Legal Forms

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