Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 03
City of Tagbilaran

MARIA LAYLA DE LUMA,

Plaintiff

-versus- Civil Case No._______

For: Unlawful Detainer

RONNIE DAYANG-DAYANG,
Respondent

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

COMPLAINT

COMES NOW, the plaintiff by the undersigned counsel to this

most Honorable Court, MOST RESPECTFULLY STATES THAT;

1. Plaintiff is of legal age, Filipino, with residence and postal

address at Marupok Street, Tagbilaran City where she may
be served notices and other court processes;

2. Respondent is of legal age, Filipino, with residence and

postal address at Barangay Mainit, Tagbilaran City, where
he may be served summons and other court processes;

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

apartment situated at Masarap Village, Tagbilaran City and
now leased and occupied by the respondent;

4. Plaintiff and Respondent had known each other for a long

time having studied in the same college and have been
friends since then;

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5. The respondent leases and occupies the said apartment
from January 1, 2014 until December 31, 2016 as agreed
upon between the plaintiff and the respondent in the lease
contract executed on January 1, 2014 under the express
obligation to pay a monthly rental of P 6,000.00; (Copy of
Contract of Lease is hereto attached as Annex A)

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

the building has been terminated on December 31, 2016 and
has not been renewed or extended;

7. During the course of the respondents occupation of the

said apartment, respondent has failed to pay her rentals for
the months of August, September, October, and November
2015, and April, May and June, 2016;

8. Respondent has continued to occupy the said apartment

notwithstanding the fact that her contract of lease has been
terminated on December 31, 2016 thus depriving the plaintiff
from having the said apartment leased by other persons;

9. Several demands to vacate was made by plaintiff to

respondent, although orally, but respondent refused to
vacate the said apartment and return possession to the
plaintiff;

10. On January 01, 2017, plaintiff sent a letter to respondent

as a last and final demand for respondent to vacate plaintiffs
apartment; (Copy of Demand Letter is hereto attached as
Annex B)

11. Until now Respondent still refuse to vacate and restore

possession and pay his rentals for the months of August,
September, October, and November 2015, and April, May
and June, 2016 during his occupation of the apartment;

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 12. Thus, Respondent is unlawfully withholding possession of
the subject apartment from the plaintiff despite last and final
demand, to the damage and prejudice of the plaintiff;

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

PRAYER

WHEREFORE, premises considered, it is most respectfully

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

1. For the restitution of the abovementioned apartment;

2. For the payment of FORTY TWO THOUSAND (P 42,000.00)

PHILIPPINE CURRENCY, representing the arrears of rent
now overdue.

3. To pay the costs for this suit.

Other reliefs just and equitable under the premises are likewise
prayed for.

Tagbilaran City,Bohol, Philippines, March 18, 2017

.
ATTY. BITTER N. LOVE
COUNSEL FOR PLAINTIFF
Barangay Walang Forever, Tagbilaran City
ROLL NO. 48511 / 24 Jan 2015
IBP Lifetime Roll No.: 816036/ 25 Jan 2015
MCLE COMPLIANCE No. III-004319 / 8 Aug 2016
PTR No.: 885167; 3/14/15; Tagbilaran City

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

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING

I, MARIA LAYLA DE LUMA, of Legal age, single, Filipino

Citizen and a resident at Marupok Street, Tagbilaran City, after
being sworn according to law, hereby 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
Court.

MARIA LAYLA DE LUMA

Affiant

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 SUBSCRIBED AND SWORN TO BEFORE ME, a notary public
in and for the Province of Bohol this 18th day of March 2017. Affiant
personally came and appeared with her Professional Regulations
Commission ID Number 128-957-320 issued by Professional
Regulations Commissions Office of the Province of Cebu on January
24, 2010 at Cebu City, bearing her photograph and signature, known
to me as the same person who personally signed this foregoing
instrument before me and avowed under the penalty of law to the
whole truth and contents of the said instrument.

ATTY. CARDO DALISAY

Probinsyano Street, Tagbilaran City
COMMISSION NO.: 1234-1234
NOTARY PUBLIC for Tagbilaran City
UNTIL December 31, 2018
OFFICE: Big Bldg, Door 308, Tagbilaran City
ROLL NO. 48511 / 24 Jan 2005
IBP Lifetime Roll No.: 816037/ 25 Jan 2005
MCLE COMPLIANCE No. III-004319 / 10 Aug 2018
TIN 128-957-329

Doc. No. 321

Page No. 3
Book No. 567
Series of 2017