Republic of the Philippines

MUNICIPAL TRIAL COURT

Branch ____,
6th Judicial Region
Iloilo City

JUAN SANTOS CRUZ

Plaintiff,

-versus- CIVIL CASE No. Q-12345

For: EJECTMENT (FORCIBLE ENTRY)

MARIO CO ROSA
Defendant.
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C O M PLAI N T

PLAINTIFF, through counsel, most respectfully states:

1. Plaintiff JUAN SANTOS CRUZ, is residing at Commision
Civil St., Jaro, Iloilo where he may be served with court order and
other processes;

2. Defendant MARIO CO ROSA is a resident Commision Civil

St., Jaro, Iloilo, where he may be served with summons, order and
other court processes;

3. That plaintiff had been in lawful and peaceful possession of a

house and lot situated at Commission Civil, Jaro, Iloilo, being
owner thereof, since May 15, 1980, until the day and incident in
the following paragraph hereof;

4. That, on or about February 14, 2017, defendants by means of

force, strategy and stealth, unlawfully entered said house ejecting

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 the encargado who, for and in behalf of the plaintiff, was staying
in and looking after the house, thereby illegally depriving plaintiff
of the possession of the premises;

5. That since the day mentioned in the preceding paragraph,

defendants have remained in illegal possession of the said premises
and, up to the present, still retain such possession thereof;

6. That the reasonable rental value of the said premises is

FIFTEEN THOUSAND PESOS (P15,000.00) a month;

WHEREFORE, it is most respectfully prayed that judgment be rendered in

favour of plaintiff and against defendants:
1. Ordering the latter to vacate premises in question and to restore the
possession to plaintiff;
2. Ordering defendants to pay plaintiff P15,000.00 a month, from the
time of forcible entry to the time possession is returned to the
plaintiff;
3. Pay the cost of this suit.

Plaintiff prays for such other remedies and reliefs as may be deemed just
and equitable under the premises.

Iloilo City, Philippines, March 01, 2017.

ATTY. DIANAH JANE L. HUELE

Counsel for Plaintiff

Alibogha Munez & Duremdes Law Office

2nd Floor, The Palladium, Megaworld,

Mandurriao, Iloilo City

Attorneys Roll No. 61987

IBP No. 169867, 05/17/16, lloilo City

PTR No.2543572, 05/18/16 , lloilo City

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 MCLE Compliance No. 1110016263,
5/18/16

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING

I, JUAN SANTOS CRUZ,of legal age, after having been duly sworn in
accordance with law, 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

___________________________

Affiant

SUBSCRIBED AND SWORN to before me this ___ day of

__________ 200_ at _________________ affiant exhibiting to me his
Community Tax Certificate No.____________________ issued on
________________ 200_ at ______________ City.

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Doc. No. ;
Page No. ;
Book No. ;
Series of 200_.

ATTY. DIANAH JANE L. HUELE

Counsel for Plaintiff

Alibogha Munez & Duremdes Law Office

2nd Floor, The Palladium, Megaworld,

Mandurriao, Iloilo City

Attorneys Roll No. 61987

IBP No. 169867, 05/17/16, lloilo City

PTR No.2543572, 05/18/16 , lloilo City

MCLE Compliance No. 1110016263,

5/18/16