Republic of the Philippines

MUNICIPAL TRIAL COURT (IN CITIES)

(Name of City / Municipality)

(NAME OF PLAINTIFF)
Plaintiff,

-versus- Civil Case No. ______

For: Unlawful Detainer

(NAME OF DEFENDANT),
Defendant.
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COMPLAINT
PLAINTIFF, by counsel, and unto this Honorable Court, most
respectfully allege: -THAT-

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

at (Residential address of plaintiff) where he may be served notices and
other court processes;

2. Defendant is of legal age, Filipino, with residence and postal address

at (Residential address of defendant), where he may be served summons
and other court processes;

3. Plaintiff is the absolute owner and lessor of that certain townhouse situated
at (Location of property) and now leased and occupied by the Defendant;

4. The Defendant leases and occupies the said townhouse from March 1, 2012
until February 28, 2017 as agreed upon between the plaintiff and the
Defendant in the lease contract executed on March 1, 2012 under the
express obligation to pay a monthly rental of P20,000.00; (Contract of Lease
attached as Annex “A”)
5. The lease contract of the Defendant for the occupation of the building has
been terminated on February 28, 2017 and has not been renewed or
extended;

6. During the course of the Defendant’s occupation of the said townhouse,

Defendant has failed to pay his rentals for the months of June 2016 to
February 2017;

7. Defendant has continued to occupy the said townhouse notwithstanding the

fact that her contract of lease has been terminated on February 28, 2017
thus depriving the plaintiff from having the said townhouse leased by other
persons;

8. Several demands to vacate was made by plaintiff to Defendant, both oral and
written(Demand letter attached as Annex “B”), but Defendant refused to
vacate the said townhouse and return possession to the plaintiff;

9. Until now Defendant still refuses to vacate and restore possession and pay
her rentals for the months June 2016 to February 2017 during her occupation
of the townhouse;

10. Thus, Defendant is unlawfully withholding possession of the subject

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

11. Before filing of this complaint, the dispute has been referred to the Lupong
Tagamayapa of (Name of City or Municipality) but the parties failed to
arrive at an amicable settlement; (Certificate to File Action 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 townhouse;

2. For the payment of ONE HUNDRED THOUSAND (PhP180,000.00) PESOS,

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.

(Place of Filing), Philippines, (Date of Filing).

(NAME OF LAW OFFICE)

Counsel for Plaintiff
(Address of law office)

By:

(NAME OF LAWYER)
Roll No.: ____________
PTR No: ____________
IBP No.: ____________
MCLE Compliance No.: ____________

ATTACH:

Verification and Certification of Non-forum Shopping

Annexes