COMPLAINT
1. The Plaintiff is of age and a resident of Block 32 Lot 31 Clarity Street Pag
Ibig Homes Buhangin Davao City while the defendant is also of age, with
residence at Block 23, Lot 13, Malabo St., Boulevard, Davao City where he
may be served with summons and other court processes;
4. In the Contract, the Lessor leases and occupies the back portion of the
building under the express obligation of paying a monthly rent of one
hundred thousand pesos (P100,00.00). Subsequently, the contract was
renewed for the same term and amount commencing January 25, 2010 to
January 25, 2020.
6. The Defendant refused to accept the new Contract and insisted on the
validity of the old Contract they signed with the Spouses in 2000.
7. On January 5, 2016, the defendant failed to pay the rents. Without any
legal justification, defendant continuously refuses to pay the said amount
despite repeated oral demands.
11. A new demand letter was sent and received personally by the
defendant on January 5, 2018. A copy of the final demand letter to pay the
arrears is here attached as ANNEX H.
By:
EUNICE L. AMBROCIO
Rolls of Attorneys No. 2008-000088
PTR No. 9189180/06-25-2019/ Davao City
IBP Lifetime Roll No. 918918/05-25-2018/ Metro Manila
MCLE Compliance No. – Exempt (New Lawyer, 2018)
2. I have read and understood the contents hereof of this Petition for
Review, and the facts herein alleged are true and correct of my own
knowledge and based on available verifiable records;
__________________
Affiant
SUBSCRIBED and SWORN TO before me this 6th day of February
2019 at Davao City, Philippines, affiant exhibiting to me her SSS ID with ID
No. 123-234 issued by the Social Security System, as competent evidence of
her identity, and she personally acknowledged to me that the foregoing
“Petition” is her free and voluntary act and deed. Machine copy of this SSS
ID is hereto attached.
I, Spange Bab of legal age, Filipino, and a resident of Block 32, Lot 31
Clarity Street Pag Ibig Homes Buhangin Davao City, after having been
duly sworn to in accordance with law hereby depose and say that:
__________________
Affiant
SUBSCRIBED AND SWORN TO BEFORE me this 6th day of
February, 2019 at Davao City, Philippines.