Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

FIRST JUDICIAL REGION
Branch 2
Baguio City
,

CIVIL CASE NO.: 23789

Plaintiff,
- versus -

FOR: UNLAWFUL
DETAINER
Defendant,

x--------------------- ---x
COMPLAINT
COMES NOW the plaintiff, by and through the
undersigned counsel, and unto the Honorable Court, most
respectfully manifest that:
1. The plaintiff is of legal age, Filipino citizen,
married and with residence at No. 45 Zamora
Street, Baguio City within the jurisdiction of
this Honorable Court, where he may be served
with notices and processes of the Honorable
Court;
2.

Defendant, is of legal age, Filipino citizen

single and a resident of No. 29 Lower
Magsaysay, Baguio City where he may be
served with summons, notices, orders and
other processes of the Honorable Court;

3. The plaintiff is the owner of a land over which

an apartment had been constructed located
No. 30 Lower Magsaysay, Baguio City.
4. By virtue of a contract of lease, the plaintiff leased
unto the defendant the aforesaid apartment for a
consideration of P4,500.00 a month as rental to be
paid within the first ten (10) days of each month
starting January 1, 2014;
5. The defendant failed to pay the agreed rental for
several months starting
November 1, 2015 up to the present;
Page 1 of 5

6. On January 3, 2016, 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. Having been constrained to bring this suit to protect
her rights, plaintiff engaged the services of the
undersigneds Law Office for which she agreed to pay
attorneys fees in the amount of TWENTY THOUSAND
(Php 20,000.00) PESOS representing acceptance fee
and TWO THOUSAND ( PHP 2,000.00) PESOS per
court appearance;
PRAYER
WHEREFORE and in view of the foregoing, it is most
respectfully prayed that, after hearing, judgment be
rendered:
1. To issue an order in favor of the plaintiff and
against the defendant ordering the latter to
immediately vacate and refrain from entering and
doing her illegal acts on the property of the
plaintiff;
2. To order the defendant to pay the unpaid rentals
from November 1, 2015 up to present;
3. To order the defendant to pay the plaintiff the
amount of P20,000.00 by way of lawyers
acceptance fee and P2,000.00 per court
appearance;
Such other relief just and equitable under the premises is
likewise prayed for.
Baguio City, Philippines this 15th day of March 2013.

Page 2 of 5

Counsel for Plaintiff

No. 23, Otek Square, Otek Street, Baguio City
Roll No. 65321; April 10, 2015
PTR No. 2091162; January 10, 2016, Baguio City
IBP No. 2311755; January 15, 2016, Baguio-Benguet Chapter
M.C.L.E. Compliance No. III-098765, January 11, 2015, Pasig
City
Doc. No.2;
Page No. 2;
Book. No. II;
Series of 2016.

Page 3 of 5

VERIFICATION & CERTIFICATION OF NON-FORUM

SHOPPING
Republic of the Philippines )
Baguio City
) S.S.
I, , of legal age, Filipino citizen, single and resident of No.
123 P. Burgos, Baguio 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 hereunto affixed my
signature this 15th of March 2016, in the City of Baguio.

SUBSCRIBED AND SWORN to before me this 15 day

of March, 2016, in City of Baguio.
Notary Public
Page 4 of 5

Notarial Commission expires on December 31, 2017

Roll No. 65321; April 10, 2015
PTR No. 2091162; January 10, 2016, Baguio City
IBP No. 2311755; January 15, 2016, Baguio-Benguet Chapter
M.C.L.E. Compliance No. III-098765, January 11, 2015, Pasig
City
Cell No. 09-123-456-789, TIN: 321-654-000
Doc. No.2;
Page No. 2;
Bk. No. II;
Series of 2016.

Page 5 of 5