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Complaint for Unlawful Detainer Sample

solitaryrebel.blogspot.com /2012/09/complaint-f or-unlawf ul-detainer-sample.html

REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT City of Manila Branch 1 KRUL ACOSTA, Plaintif f , -versusMEGAN VITUG, Def endant. CIVIL CASE No. 98765 FOR: Unlawf ul Detainer

x-----------------------------------x COMPLAINT COMES NOW, the plaintif f , through the undersigned counsel and unto this Honorable Court, most respectf ully avers: 1. That the plaintif f , KRUL ACOSTA, is of legal age, Filipino citizen, single, with residence and postal address at 123 Benitez Street, Manila; 2. That the def endant, 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; 3. The plaintif f 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 plaintif f leased unto the def endant the af oresaid apartment f or a consideration of P5,000.00 a month as rental to be paid within the f irst ten (10) days of each month starting November 3, 2011; 5. The def endant f ailed to pay the agreed rental f or several months starting February 19, 2012 up to the present; 6. On May 3, 2012, the plaintif f sent a letter of demand to vacate the apartment which was received by the def endant 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 def endant f ailed and still ref used to pay the agreed amount of rentals and to vacated the apartment;

8. By reason of f ailure of the def endant to vacate the premises and to pay the unpaid rentals, the plaintif f was compelled to f ile this complaint engaging the services of counsel in the amount of P10,000.00. WHEREFORE, premises considered, it is most respectf ully prayed unto this Honorable Court that, af ter hearing, judgment be rendered ordering the def endant: 1. To vacate the subject premises; 2. To pay the amount of P5,000.00 per month as compensation f or the reasonable use of the subject premises until they f inally vacate the said premises; 3. To pay the plaintif f the cost of the suit. City of Manila, September 24, 2012. REYES, TOLENTINO AND CRUZ LAW OFFICE Counsel f or the Plaintif f Unit 123, Victoria Tower I Taf t 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, af ter having been duly sworn to in accord Nance with law do hereby depose and say: 1. That I am the plaintif f in the above-entitled case; 2. That I have caused the preparation of the f oregoing 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 certif y 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 thereaf ter that a similar action or proceeding has been f iled or is pending, I hereby undertake to report that f act within f ive (5) days theref rom to the court or agency where the original pleading and sworn certif ication contemplated herein have been f iled; 6. I executed this verif ication/certif ication to attest to the truth of the f oregoing f acts and to comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court. IN WITNESS WHEREOF, I have hereunto af f ixed my signature this 24th of September 2012, in the City of Manila. KRUL ACOSTA SUBSCRIBED AND SWORN to bef ore me this _______ day of September, 2012, in the City of Manila, af f iant exhibiting to me his Drivers License No. 12345 issued by the Land Transportation Of f ice 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.