Republic of the Philippines

National Capital Judicial Region

Metropolitan Trial Court
Branch 1, New Yark City


MICHAEL CORLEONE,
Plaintiff,

--Versus-- Civil Case No. 12335
For: Unlawful Detainer
BRUNO AND MARIA TATTAGLIA,
Defendants.

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


COMPLAINT
Plaintiff, thru counsel, respectfully avers that:

1. The plaintiff is of age, married and a resident of Long Island, New Yark
City. The defendants are also of age, with residence at Northern, Sicily
City, where they may be served with summons and other court processes;

2. The plaintiff is an agent and partly owner of a mansion located at Long
Island, New Yark, currently being occupied by the defendants;
3. On January of 2006, the plaintiff and the defendants executed a Deed of
Absolute Sale for the said house and lot amounting to P2.5 million;



4. The full amount was not paid but defendants were allowed by the
plaintiff to occupy the premises agreeing that the title will only be
transferred upon the payment of the balance amounting P338,000.00;

5. On August 2, 2010, the plaintiff legally demanded for the unpaid balance.

6. On April 15, 2013, a final demand to pay and vacate was sent, but the
defendants refused to comply. Thus, the Deed of Absolute Sale was
cancelled resulting to the illegal possession of the house and lot by the
defendants. The plaintiff also demanded for the payment of monthly
rentals;
7. By reasons already mentioned, the plaintiff was compelled to file this
complaint, resulting for the need of legal service.


PRAYER.
WHEREFORE, premises considered, it is most respectfully prayed unto this
Honorable Court that, after hearingthe case, plaintiff requests judgment
against the defendants:

a. To vacate the said property;
b. To pay the monthly rentals, legal interest, forfeiture of agreement/
illegal possession of the premises;
c. To pay the costs of the suit;
d. To pay costs incurred in the proceeding;
e. Any further relief that the court may consider just and proper

Other reliefs just and equitable are likewise prayed for.
New Yark, Philippines, April 24 2014.




Glenn David Butardo
Counsel for the Plaintiff
PTR-1234567; 1-02-2014; New Yark City
IBP-429053; 1-06-2013, New Yark City
Roll 22 MCLE IV-99999
Unit No. 1, Godfather corner Marlon Brando St.,
Mario Puzo subdivision, New Yark City, Philippines
Long Island


VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines

I, MICHAEL CORLEONE, of legal age, Filipino citizen, single and
resident of Long island, New Yark 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;


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 hereby affixed my signature this March,
6 2014, in the City of NewYark

MICHAEL CORLEONE


I, Glenn Butardo, am the Counsel in the above-entitled action. I have
read the foregoing Complaint and know the contents thereof. The same is
true of my own knowledge, except as to those matters which are therein
alleged on information and belief, and as to those matters, I believe it to be
true.
I declare under penalty of perjury that the foregoing is true and correct and
that this declaration was executed at Long Beach, California
.
ATTY. Glenn D. Butardo
Attorney at Law
My Commission Expires June. 6, 2226
Roll of Attorney No. 666
PTR-1234567; 1-02-2014; New Yark City
IBP-429053; 1-06-2013, New Yark City
Doc. No. ________
Page No. _______
Book No. _______
Series of 2014