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REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT


City of Manila
Branch 1

JUAN DELA CRUZ,


                         Plaintiff,
                                                                              CIVIL CASE No. 98765
                         -versus-                                        FOR: Unlawful Detainer

DONALD TRUMP,
                         Defendant.

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

COMPLAINT

  COMES NOW, the plaintiff, through the undersigned counsel and


unto this Honorable Court, most respectfully avers:

1. That the plaintiff, JUAN DELA CRUZ, is of legal age, Filipino


citizen, single, with residence and postal address at 123 Benitez
Street, Manila;
2. That the defendant, DONALD TRUMP, 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 plaintiff 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 plaintiff leased unto the
defendant the aforesaid apartment for a consideration of
P5,000.00 a month as rental to be paid within the first ten (10)
days of each month starting November 3, 2017;
5. The defendant failed to pay the agreed rental for several months
starting February 19, 2017 up to the present;

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6. On May 3, 2017, 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.

  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 the amount of P5,000.00 per month as compensation for
the reasonable use of the subject premises until they finally vacate
the said premises;
3. To pay the plaintiff the cost of the suit.

  City of Manila, November 27, 2017.

                      XXX OFFICE
                                          Counsel for the Plaintiff
                                         Unit 123, Victoria Tower I
                                               Taft Avenue, Manila

                                                                    By:
                                                                     ABC DEFs
                                                        Roll of Attorney No. 98765
                                      IBP No. 12345/2-5-17/Manila
                                                   PTR No. 87654/12-22-17/Manila

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

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Republic of the Philippines )
City of Manila                     ) S.S.

  I, JUAN DELA CRUZ, of legal age, Filipino citizen, single and


resident of 123 Benitez Street, Manila, after having been duly sworn to
in accordance 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 27th of November 2017, in the City of Manila.
                                                       
JUAN DELA CRUZ

          SUBSCRIBED AND SWORN to before me this 27 day of


November, 2017, in the City of Manila, affiant exhibiting to me his
Driver’s License No. 12345 issued by the Land Transportation Office on
April 8, 2017 at the City of Manila.

                                             ATTY. NO CASE
                                                     Notary Public
                            My Commission Expires Dec. 31, 2018
                          Roll of Attorney No. 34567
                   IBP No. 12345/2-5-17/Manila
                                      PTR No. 87654/12-22-17/Manila

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Doc. No. 1
Page No. 1
Book No. 1
Series of 2017

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