REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT IN CITIES City of Surigao Branch 1 PEDRO PEREZ, Plaintiff, -versusJUAN CRUZ,

Defendant. x-----------------------------------x COMPLAINT COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most respectfully avers: 1. That the plaintiff, PEDRO PEREZ, is of legal age, Filipino citizen, single, with residence and postal address at 0022 P. Reyes Street, Surigao City; 2. That the defendant, JUAN CRUZ, is of legal age, Filipino citizen, single, with residence and postal address at 121 Kaimo Street, Surigao, where they may be served with summons and other court processes; 3. The plaintiff is the owner of a land over which a commercial building had been constructed located 0587 Narciso Street, Surigao City; 4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid commercial building for a consideration of P25,000.00 a month as rental to be paid within the first five (5) days of each month starting June 2, 2011; 5. The defendant failed to pay the agreed rental for several months starting March 5, 2013 up to the present; 6. On April 2, 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; 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; CIVIL CASE No. 123456 FOR: Unlawful Detainer

8. 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 P30,000.00. 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 P25,000.00 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 Surigao, December 12, 2013.

CLAYTON M. DELGADO Counsel for the Plaintiff 321 J.P. Rizal St., Surigao City Roll of Attorney No. 65432 IBP No. 12345/1-15-13/Surigao PTR No. 98765/1-22-13/Surigao

VERIFICATION AND CERTIFICATION Republic of the Philippines ) City of Surigao ) S.S. I, PEDRO PEREZ, of legal age, Filipino citizen, single and resident of 0022 P. Reyes Street, Surigao City, after having been duly sworn to in accordance 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; IN WITNESS WHEREOF, I have hereunto affixed my signature this 12th of December 2013, in the City of Surigao.

PEDRO CRUZ SUBSCRIBED AND SWORN to before me this 12th day of December, 2013, in the City of Surigao, affiant exhibiting to me his PRC ID No. 12345 issued by the Professional Regulation Commission on July 11, 2012 at the City of Butuan.

Notary Public Doc. No. ________ Page No. _______ Book No. _______ Series of 2013.

REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT IN CITIES City of Surigao Branch 1 PEDRO PEREZ, Plaintiff, -versusJUAN CRUZ, Defendant. x-----------------------------------x ANSWER COMES NOW, the defendant, through the undersigned counsel and unto this Honorable Court, most respectfully avers: 1. That he ADMITS averment in paragraph 2, 3, 4 of the complaint; 2. Defendant specifically denies the allegation in paragraph 5 of the complaint, the truth being that the plaintiff has an outstanding obligation to the defendant in the amount of Two Hundred Fifty (Php250,000.00) Pesos that would compensate the rental dues to the said plaintiff; 3. Defendant has no knowledge or information to form a belief as to the truth of the averment in paragraphs 6, 7 and 8 of the complaint. By way of special and affirmative defenses, the defendant avers: 1. The obligation has been paid. By way of counterclaim, defendant alleges: 1. That by virtue of this unwarranted and malicious act initiated by the plaintiff, the defendant was forced to engage the services of counsel in the sum of twenty-thousand pesos (P20,000). WHEREFORE, the defendant respectfully prays that the complaint be dismissed with costs against the plaintiff. City of Surigao, December 20, 2012. CIVIL CASE No. 123456 FOR: Unlawful Detainer

MARK SANTOS Counsel for the Defendant 123 Kaimo St., Surigao City Roll of Attorney No. 23456 IBP No. 54321/1-11-13/Surigao PTR No. 345223/1-24-13/Surigao

RECEIVED COPY this 23rd day of December, 2013.

CLAYTON M. DELGADO Counsel for the Plaintiff 321 J.P. Rizal St., Surigao City Roll of Attorney No. 65432 IBP No. 12345/1-15-13/Surigao PTR No. 98765/1-22-13/Surigao