REPUBLIC OF THE PHILIPPINES MUNICIPAL TRIAL COURT NATIONAL CAPITAL JUDICIAL REGION CITY OF MANILA Branch 11 JEFFREY JAY

C. GONZALES, Plaintiff, -VersusCivil case No.123 For : Unlawful Detainer JUAN TAMAD, Defendant. x--------------------------------------------------------------x

COMPLAINT

Plaintiff, by counsel to this Honorable Court, most respectfully states:

1. That the plaintiff, JEFFREY JAY GONZALES, is of legal age,

Filipino citizen, single, with residence and postal address at 123 Benitez Street, Manila;

2. That the defendant, JUAN TAMAD, is of legal age, Filipino citizen,

single, with residence and postal address at 456 Modesto Street, Manila, 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 654 San Pedro Street, Manila;
4. By virtue of a contract of lease, the plaintiff leased unto the

defendant the aforesaid apartment for a consideration of P5,000.00 a month as rental to be paid within the first ten (10) days of each month starting November 3, 2012; starting February 19, 2013 up to the present;

5. The defendant failed to pay the agreed rental for several months

6. On May 3, 2013, 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;

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 vacate the apartment;

Page -27. 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 P10,000.00. PRAYER 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 P5,000.00 per month as compensation for the reasonable use of the subject premises until they finally vacate the said premises; 3. Ordering the defendant to reimburse the plaintiff for attorneys fee in the amount of Php. 100,000.00 by way of attorneys fee plus Php. 5,000.00 as appearance fee for every hearing actually attended in court by counsel, and 4. Cost of suit. Other relief and remedies available under the premises are likewise prayed for. City of Manila September 26, 2012.

Jay C. Gonzales Counsel for the Palintiff Rizal Street, Makati City IBP# 123456/7-8-9/Mkti.Chapter III PTR# 654321/7-9-8/ Manila Roll No. 123456

MCLE Exemption No. III-123456 Tel. No. 123-4321

Page -3-

VERIFICATION/CERTIFICATION

I, ________

Copy Furnished by Registered Mail with Return Card:

_______________________ Counsel for Defendant J.P Rizal Street City of Manila

Official Receipt No.________ Post office of City of Manila Date of Mailing ___________

CERTIFICATION/EXPLANATION (Under Section 11, Rule 13 of the Rules of Civil Procedure)

That a copy of this pleading was sent to the defendant by mail and not by personal service as required by law, due to distance and lack of personnel to deliver the same personally.

SUBSCRIBED AND SWORN to before me this 22nd day of September 2013 at Quezon City, affiant exhibiting to me his Community Tax Certificate No.123 issued on September 1, 2013 at Quezon City.

(Notary Public)

Doc. No. Page No. Book No. Series of 2013