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Republic of the Philippines

METROPOLITAN TRIAL COURT


National Capital Judicial Region
Branch 13, Manila

PEDRO C. LABO,
Plaintiff,

- versus -
Civil Case: 5432
FOR:
Unlawful Detainer
JOSE B. LINAW,
Defendant.
x-------------------x

COMPLAINT

Plaintiff, by counsel, states:

The Parties

1. Pedro is a Filipino, single, and resides at 143


Vicente Cruz St., Sampaloc, Manila.

2. Jose, on the other hand, is a Filipino, married, and


resides at 789 Mayhaligue St. Binondo, Manila, where he
may be served with summons and other court processes.

Causes of Action

3. The parties executed a lease contract on 28 August


2005 for Jose’s use of a house and lot owned by Pedro
located in Binondo. A copy of this contract is attached as
Annex A. Part of the agreement is the payment of monthly
rent in the amount of PhP15,000.00.
4. While initially Jose paid his obligation, he
suddenly breached his undertaking by not paying his
rental beginning January 2007. Oral and written demands
to pay his obligation fell on deaf ears. To date, his unpaid
obligation ballooned to PhP120,000.00. A copy of the last
demand letter urging him to pay his arrears and vacate the
premises is attached as Annex B, while a copy of his latest
unpaid billing is enclosed as Annex C.

5. Because of Jose’s unjustified refusal to heed his just


demands, Pedro was constrained to institute this suit, incur
litigation expenses to be proved during trial and retain the
services of a lawyer for a fee of PhP40,000.00, all of which
he deserves to be reimbursed.

Relief

ACCORDINGLY, Pedro asks that judgment be


rendered ordering Jose and all other persons acting on his
behalf to:

1. Vacate the house and lot subject of this complaint;


2. Pay plaintiff the sum of PhP120,000.00 as unpaid
rentals with legal interest from the date the
complaint is filed; and,
3. Pay him litigation expenses and attorney’s fees of
PhP40,000.00.

Other reliefs just and equitable are also prayed for.

Manila, 7 August 2009.

(SGD.) MARCELO B. FERNANDO


Counsel for Plaintiff
Suite 1234 Richmond Tower
E. Rodriguez Avenue, Quezon City
Roll of Attorney 35677
MCLE Compliance Certificate II; 5-11-08
IBP 14344; 1-19-07; Quezon City
PTR 867765; 1-20-07; Quezon City

Verification/Certification

I, Pedro Labo, state under oath that I have read the


above complaint and the allegations in it are true and
correct of my personal knowledge and/or based on
authentic record. I also certify under oath (a) that I have
not previously filed any action involving the same issues in
any court, tribunal or quasi-judicial agency; (b) that, to the
best of my knowledge, no such action is pending in any of
them; and (c) if I should learn of the filing of such action, I
shall report it to the court within five days from notice.

Manila, 7 August 2009.

Affiant

SIGNED AND SWORN before me this 14 August


2008 at Manila, after affiant exhibited to me his Passport
JJ2003*, issued on 09 January 2007 at Manila.

(SGD) JUAN C. MENDOZA


Notary Public for Manila
Suite 212 Burke Building, Escolta, Manila
Commission Serial 54342
Until Dec. 31, 2008
Roll of Attorney 38718
PTR 56789; 1-12-08; Manila
IBP 24680; 1-12-08; Manila
Doc. 12;
Page 8;
Book II;
Series of 2008.