Nina Joy L.

Natividad LO3

REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT
City of Bacolod
Branch 5
ANTON NOBLE,
Plaintiff,
C
IVIL CASE No. 98765
-versus- FOR
: Unlawful Detainer

ANDREA AGONCILLO,
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel

and unto this Honorable Court, most respectfully avers:

1. That the plaintiff, ANTON NOBLE, is of legal age, Filipino citizen,

single, with residence and postal address at Camella Subdivision,
Mandalagan, Bacolod City
2. That the defendant, ANDREA AGONCILLO, is of legal age,
Filipino citizen, single, with residence and postal address at B1 L2
Poshville Subdivision, Bacolod City, where they may be served with
summons and other court processes;
3. The plaintiff is the owner of the property where the defendant
currently resides;
4. By virtue of a contract of lease, the plaintiff leased unto the
defendant the aforementioned property which they both agreed upon
and was duly signed by the two parties on June 27 2014, as shown in
their Contract of Lease.
5. Item No. 20 of the contract which the defendant signed expressly
provides that she will only be occupying the property for one (1)
year, after which, she will vacate the house when that term expires.
The contract also provides that the defendant should take care of the
property and its premises with utmost diligence ;
6. Upon coming home from abroad on June 29, 2015, plaintiff
discovered that the defendant failed to vacate the premises even
after the the contract has expired;
Nina Joy L. Natividad LO3

7. Defendant had made drastic changes on the property, a mini grocery

store in the original building structure of the house unit., thereby
violating the terms of the contract.;
8. Defendant claimed that it was a DEED OF SALE which they
signed and not a CONTRACT OF LEASE and therefore, she is
the new owner of the house unit.;
9. On August 20,2015, despite said letter of demand which was
repeated by oral demands, the defendant failed and still refused to
vacate the property, even inviting relatives to stay with her;
10.By reason of failure of the defendant to vacate the premises, 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 for the damages and changes made on the property;
3. To pay the plaintiff the cost of the suit.

City of Bacolod, March 30, 2015.

NATIVIDAD, ARRIOLA AND FERNANDEZ

LAW OFFICE
Counsel for the Plaintiff
Unit 123, O Residences
Mandalagan, Bacolod

By:
Nina Nativida
d
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.
Nina Joy L. Natividad LO3

11. I, ANTON NOBLE, of legal age, Filipino citizen, single

and resident of Camella Subdivision, Mandalagan, Bacolod City,
after having been duly sworn to in accord Nance with law do hereby
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 20th of March 2015, in the City of Manila.

KRUL ACOSTA

SUBSCRIBED AND SWORN to before me this _______ day of

March, 2015, in the City of Manila, affiance exhibiting to me his Drivers
License No. 12345 issued by the Land Transportation Office on April 8,
2014 at the City of Manila.

ATTY. NO CASE
Notary Public
My Commission Expires Dec. 31, 2018
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila
Nina Joy L. Natividad LO3

Doc. No. ________

Page No. _______
Book No. _______
Series of 2012