REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region

REGIONAL TRIAL COURT
BRANCH 76, QUEZON CITY

Mei Arry,
Plaintiff,

Civil Case No. 0011

– versus –
Ejectment Case

Rey Tenante,
Respondent.

X -------------------------------------------------------- X

COMPLAINT

Plaintiff, by counsel, respectfully states that:

1. Respondent, Rey Tenante, a Filipino citizen, of legal age,
married, and a resident of #262 Rizal Avenue, Davao City;

2. Plaintiff, Mei Arry, Filipino citizen, of legal age, married, and a

resident of #751 Mapayapa St. Teacher’s Village, Quezon City;

3. Plaintiff is the absolute owner and lessor of that certain property

situated at #750 Mapayapa St. Teacher’s Village, Quezon City
and now leased and occupied by the respondent;

4. The respondent leases and occupies the said property from

February 1, 2014 until February 1, 2016 as agreed upon between
the plaintiff and the respondent in the lease contract executed in
February 1, 2014 under the express obligation to pay a monthly
rental of P10,000; (A copy of Contract of Lease is hereto
attached as Annex “A”)

5. The lease contract of the respondent for the occupation of the

property has been terminated on February 1, 2016 and has not
been renewed or extended;
 6. During the course of the respondent’s occupation of the said
property, respondent has failed to pay his rentals for the months
of July, August, September, October, November 2015 and
January 2016;

7. Respondent has continued to occupy the property amidst the fact

that the contract of lease has been terminated on February 1,
2016 thus depriving the plaintiff from having the said property be
used as office for his business venture;

8. Several demands to vacate was made by the plaintiff to

respondent, although, orally, but refused to vacate the said
property and demand for respondent to vacate plaintiff’s
property;

9. On February 15, 2016, plaintiff sent a letter to respondent as a

last and final demand for respondent to vacate the premises;
(copy of demand letter is hereto attached as Annex “B”)

10. Until now respondent still refuse to vacate and restore

possession and pay his rental for the months July, August,
September, October, November 2015 and January 2016 during
his occupation of the apartment;

11. Thus, respondent is unlawfully withholding possession of

the subject property from the plaintiff despite last and final
demand, to the damage and prejudice of the plaintiff;

12. Before filing this complaint, the dispute has been referred
to the Lupong Tagamayapa in Quezon City but the parties failed
to arrive at an amicable settlement; (Certificate to File Action is
hereto attached as Annex “C”)

WHEREFORE, premises considered, it is most respectfully prayed

of this Honorable Court that after due notice and hearing, judgement
be rendered in favor of Plaintiff:

1. For the restitution of the abovementioned property;

2. For the payment of SIXTY THOUSAND PESOS (P60,000) with

legal interest representing the arrears of rent now overdue;

3. For the damages amounting to EIGHTY THOUSAND PESOS

(P80,000) resulting from the material injury suffered by the
 plaintiff because the latter’s business plans have been delayed
despite the arrival of machineries;

4. For attorney’s fees amounting to FIFTY THOUSAND PESOS

(P50,000).

Other just and equitable reliefs are also prayed for:

Quezon City: February 18, 2016.

(Sgd.) ATTY. DEE PAPATALO

Attorney for Plaintiffs
DEE PAPATALO LAW OFFICE
142 Brgy. Laging Panalo
Quezon City, Philippines
Roll No. 124353
P.T.R. No. 1234567 / Quezon City / January 10, 2016
IBP No. 409601 / Quezon City / January 20, 2016
MCLE Compliance No. V-0012891 / Quezon City / December 12,
2015
 VERIFICATION AND CERTIFICATION AGAINST FORUM
SHOPPING
I, Mei Arry, of legal age, do hereby state that: I caused this
complaint to be prepared; I have read its contents and affirm that they
are true and correct to the best of my own personal knowledge; I
hereby certify that there is no other case commenced or pending
before any court involving the same parties and the same issue and
that, should I learn of such a case, I shall notify the court within five (5)
days from my notice.

IN WITNESS WHEREOF, I have signed this instrument on

February 18, 2016.

(Sgd.) Mei Arry

SUBSCRIBED AND SWORN TO before me in Quezon City on

this day of February 18, 2016, affiant exhibiting before me his
community tax certificate no. CC493810 issued on January 31, 2016
at Quezon City.

Sgd. N. O. Tario
Notary Public
Until December 31,
2016
PTR No. 525253 /
01.10.16
Issued at Quezon City
On January 31, 2016

Doc. No.
Page No.
Book No.
Series of 2016.