REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

MUNTINLUPA CITY
BRANCH 90
Juana Change
Plaintiff
Civil Case No. 15-0005
versus
For: Unlawful Detainer
Ellaine Gorio
Defendant.
x---------------------------------x

COMPLAINT
Plaintiff, thru counsel, respectfully avers that:
1. The plaintiff is of age and a resident of Solano Hills, Sucat, Muntinlupa City, while the
defendant is also of age, with residence at J. De Leon St., La Huerta, Paranaque City
where he may be served with summons and other court processes;
2. The plaintiff is the absolute owner and lessor of Condominium Unit No. 304Q
located at Solano Hills, Sucat, Muntinlupa City as evidenced by pertinent
documents like tax declaration and deed of sale ( EXHIBIT A );
3. The defendant is the lessee of the condominium unit that is owned by the
plaintiff as evidenced by the written contract of lease that both parties signed
(Exhibit B);
4. The plaintiff and the defendant came up with a written Agreement of Lease on
June 5, 2015, which they both agreed upon and was duly signed by the two
parties as shown in their contract of lease (Exhibit B);
5. The defendant leases and occupies the said unit under the express obligation of paying
a monthly rent of Ten Thousand Pesos (P10, 000), payable within the first five (5) days
of each month;
6. The defendant has failed to pay the rents for several months starting October 5, 2015 up
to the present;
7. Without any legal justification, defendant continuously refuses to pay the said amount
despite repeated oral and written demands;
8. A final demand letter was sent and received personally by defendant on January 15,
2016, or more than five (5) days before the filing of this complaint. A copy of the final
demand letter to pay the arrears and to vacate the premises is here attached as Annex
C.
9. 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, it is respectfully prayed that after due hearing, judgment be rendered in
favor of the plaintiff:
a. For the restitution of the abovementioned premises; and
b. For the payment of Twenty Thousand Pesos (P20, 000), representing the arrears of rent
now overdue, with legal interest from the filing of this complaint, and costs of suit.
Other reliefs just and equitable are likewise prayed for.
Muntinlupa City, Philippines, this 30th day of January 2016.

ZOLETA, CASTILLO AND CRUZ LAW OFFICE

Counsel for the Plaintiff
Unit 123, Victoria Tower I
Alabang, Muntinlupa
By:
Atty. Jason Zoleta
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 MUNTINLUPA

) S.S.

I, Juana Change, Filipino, of legal age, residing at Solano Hills, Sucat, Muntinlupa City, after
being sworn to in accordance with law, deposes and says that:
1. I am the Plaintiff in the above-entitled case;
2. The facts stated in the above complaint are true and correct to the best of my knowledge
and authentic records;
3. I have not commenced any action or filed any claim 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 in them; and

4. If I should learn that the same or similar action or claim has been filed or is pending after
its filing, I shall report that fact within five (5) days from notice to the court or where the
complaint or initiatory pleading has been filed.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 30th of January 2016, in
the City of Muntinlupa.

JUANA CHANGE
Affiant

SUBSCRIBED AND SWORN to before me this 30th day of January, 2015, in the City of
Muntinlupa, affiant exhibiting to me her Drivers License No. 12345 issued by the Land
Transportation Office on August 19, 2012 at the City of Manila.

ATTY. JUAN DELA CRUZ

Notary Public
Commission expires on December 31, 2018
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

Doc. No. 25;

Page No. 10;
Book No. 20;
Series of 2016.