REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Calbayog
Branch __

KRUL ACOSTA,
Plaintiff, CIVIL CASE No. 98765
-versus- FOR: Unlawful Detainer

MEGAN VITUG,
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel

and unto this Honorable Court, most respectfully avers:
1. That the plaintiff, JUAN DELA CRUZ, is of legal age, Filipino citizen,
single, with residence and postal address at 123 del Pilar Street, Brgy.
Hamorawon, Calbayog City;
2. That the defendant, TERESITA ANIBAN, is of legal age, Filipino
citizen, single, with residence and postal address 123 Banuyo Street
Brgy Cental, Calbayog City, where they may be served with summons
and other court processes;
3. The plaintiff is the owner of a land over which an apartment had been
constructed located 123 Brgy. Obrero, Calbayog City;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant
the aforesaid apartment for a consideration of P15,000.00 a month as
rental to be paid within the first five (5) days of each month starting
December 3, 2018;

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5. The defendant failed to pay the agreed rental for several months
starting February 3, 2019 up to the present;
6. On April 3, 2019, the plaintiff sent a letter of demand to vacate the
apartment which was received by the defendant as shown in the
registry return receipt hereto attached as Annex “A”;
7. Despite said letter of demand which was repeated by oral demands,
the defendant failed and still refused to pay the agreed amount of
rentals and to vacated the apartment;
8. Before filing this complaint, the dispute has been referred to the
Lupong Tagapamayapa of Brgy. Hamorawon, Calbayog City but the
respondent failed to appear, hence, no amicable settlement was made.
9. By reason of failure of the defendant to vacate the premises and to pay
the unpaid rentals, the plaintiff was compelled to file this complaint
engaging the services of counsel in the amount of P20,000.00.
WHEREFORE, premises considered, it is most respectfully
prayed unto this Honorable Court that, after hearing, judgment be
rendered ordering the defendant:

1. To vacate the subject premises;

2. To pay the amount of P15,000.00 per month as compensation for the
reasonable use of the subject premises until they finally vacate the said
premises;
3. To pay the plaintiff the cost of the suit.
City of Calbayog, August 2, 2019.

ATTY. ARIEL BALTAZAR

My Commission Expires Dec. 31, 2019
Roll of Attorney No. 98765
IBP No. 12345/2-5-18/Calbayog
PTR No. 12345/12-22-18/Calbayog

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 VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Calbayog ) S.S.

I, JUAN DELA CRUZ, of legal age, Filipino citizen, single and

resident of 123 del Pilar Street, Brgy. Hamorawon, Calbayog City, after
having been duly sworn to in accord Nance with law do hereby depose
and say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and
have read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or
proceeding involving the same issues in any court, tribunal or quasi-
judicial agency and, to the best of my knowledge, no such other action
or claim is pending therein;
5. That if I should learn thereafter that a similar action or proceeding has
been filed or is pending, I hereby undertake to report that fact within
five (5) days therefrom to the court or agency where the original
pleading and sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular No.
04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature
this 2ND of August 2019, in the City of Calbayog.

JUAN DELA CRUZ

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 SUBSCRIBED AND SWORN to before me this _______ day of
September, 2019, in the City of Calbayog, affiant exhibiting to me his
Driver’s License No. 12345 issued by the Land Transportation Office
on April 8, 2018 at the City of Manila.

ATTY. ARIEL BALTAZAR

My Commission Expires Dec. 31, 2019
Roll of Attorney No. 98765
IBP No. 12345/2-5-18/Calbayog
PTR No. 12345/12-22-18/Calbayog

Doc. No. ________

Page No. _______
Book No. _______
Series of 2019.

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