Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch UV
Cebu City

HANSEL R. JALALON,
Plaintiff

CIVIL CASE NO. P 1232-15-PG

For Unlawful Detainer

- versus -

MARC REYES
Defendant
x-----------------------------------------x

COMPLAINT
COMES NOW, the plaintiff by the undersigned counsel to this
most Honorable Court, MOST RESPECTFULLY STATES THAT;

PARTIES

Page 1 of 5

1.

2.

The Plaintiff, HANSEL R. JALALON, is a Filipino citizen, of

legal age, single and a resident of Upper Level, 3 rd Door
Vailoces Apartment, Rahmann Street, Gorordo Avenue
Cebu City where she may be served with copies of
notices, orders and other papers of this Honorable Court;
The defendant, Marc Reyes, is a Filipino, of legal age,
single and a resident of Door 1 Ground Floor, T. Padilla
Street Cebu City where she may be served with copies of
notices, orders and other papers of this Honorable Court;

FACTS OF THE CASE

3.

The plaintiff is the owner of a land over which an apartment

had been constructed located Rahmann Extension, Gorordo
Avenue Cebu City;

4.

By virtue of a contract of lease, the plaintiff leased unto the

defendant the aforesaid apartment for a consideration of
P20,000.00 a month as rental to be paid within the first ten
(10) days of each month starting November 3, 2014;

5.

The defendant failed to pay the agreed rental for several

months starting February 19, 2015 up to the present;

6.

On May 3, 2015, 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.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed of this Honorable Court that judgement be rendered in favor of
the plaintiff and that after judgement:
To vacate the subject premises;

b.

To pay the amount of P20,000.00 per month as

compensation for the reasonable use of the subject premises
until they finally vacate the said premises;

c.
d.

Page 2 of 5

a.

To pay the plaintiff the cost of the suit.

Other just and equitable reliefs and remedies under the
premises.

Cebu City, Philippines, this 5th day of June 2015.

Page 3 of 5

ATTY. MARC GRETEL R. MADANGUIT

COUNSEL FOR PLAINTIFF
GF 1, Dr. 6 Rahmann Ext., Gorordo Ave. Cebu City
ROLL NO. 48511 / 24 Jan 2005
IBP Lifetime Roll No.: 816036/ 25 Jan 2005
MCLE COMPLIANCE No. III-004319 / 8 Aug 2018
PTR No.: 885167; 3/14/15; Cebu City

VERIFICATION AND CERTIFICATION OF

NON-FORUM SHOPPING
I, HANSEL R. JALALON, of Legal age, single, Filipino Citizen
and a resident of Upper Level, 3 rd Door Vailoces Apartment,
Rahmann Street, Gorordo Avenue Cebu City, after being sworn
according to law, hereby 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.

HANSEL R. JALALON
Affiant

Page 4 of 5

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public

in and for the Province of Cebu this 5th day of June 2015. Affiant
personally came and appeared with her Professional Regulations
Commission ID Number 128-957-320 issued by Professional
Regulations Commissions Office of the Province of Cebu on January
24, 2010 at Cebu City, bearing her photograph and signature, known
to me as the same person who personally signed this foregoing

instrument before me and avowed under the penalty of law to the

whole truth and contents of the said instrument.

ATTY. JUAN ISMAEL DE LA CRUZ

Ground Flr, 1st Dr, Vailoces Apartment, Rahmann
Street, Gorordo Avenue, Cebu City
COMMISSION NO.: 1234-1234
NOTARY PUBLIC for Cebu City
UNTIL December 31, 2018
OFFICE: Big Bldg, Door 308, Cebu City
ROLL NO. 48511 / 24 Jan 2005
IBP Lifetime Roll No.: 816037/ 25 Jan 2005
MCLE COMPLIANCE No. III-004319 / 10 Aug 2018
TIN 128-957-329

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Doc. No. 321

Page No. 3
Book No. 567
Series of 2015