REPUBLIC OF THE THE PHILIPPINES

MUNICIPAL TRIAL COURTS IN CITIES

City of Lipa
Branch 3
CAMILLE SUMCAD,
Plaintiff,
CIVIL CASE No. 34567
FOR: Unlawful Detainer

-versusDON RAE AMANTE

Defendant.
x-----------------------------------------x
COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto
this Honorable Court, most respectfully avers:
1. The plaintiff, CAMILLE SUMCAD, is of legal age, Filipino citizen,
single with residence and postal address at 123 Phase 1 St. Joseph
Subd. Tambo, Lipa City, Batangas;
2. That the defendant, DON RAE AMANTE, is of legal age, Filipino
citizen, married, with residence and postal address at 54 Phase 4 St.
Joseph Subd. Tambo, Lipa City, Batangas, where they may be served
with summons and other court processes;
3. The plaintiff is the owner of a land over which a house had been
constructed located at 23 Phase 3 St. Joseph Subd. Tambo, Lipa City,
Batangas;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant
the aforesaid house for a consideration of P8,000.00 a month as rental
to be paid within the first ten (10) days of each month starting
November 27, 2015;
5. The defendant failed to pay the agreed rental for several months
starting March 10, 2016 up to present;

6. On May 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 attached as Annex B;

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 vacate the apartment;
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 P10,000.00.
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 P8,000.00 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 Lipa, August 12, 2016.
GULLA, MALABANAN
AND MATENCIO LAW OFFICE
Counsel for the Plaintiff
3rd Floor MVL Building,
Lipa City, Batangas
By:

Brian Edward P. Gulla

Roll of Attorney No. 890712
IBP No. 12345/2-5-16/Batangas
PTR No. 56748/12-22-11/Batangas
MCLE Compliance No. 77865/ 07-3-15

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines)
City of Lipa
) S.S.
2

I, CAMILLE SUMCAD, of legal age, Filipino citizen, single and

resident of 123 Phase 1 St. Joseph Subd. Tambo, Lipa City, Batangas, 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
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 quasijudicial 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 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 12 th
of August 2016, in the City of Lipa.

CAMILLE SUMCAD
SUBSCRIBED AND SWORN to before me this 12 th day of August,
2016, in the City of Lipa, affiant exhibiting to me his Drivers License No.
14344 issued by the Land Transportation Office on April 8, 2014 at the City
of Lipa.

ATTY. RHEE ANN MAGNAYE

Notary Public
My Commission Expires Dec. 31, 2016
Roll of Attorney no. 67489
IBP No. 12345/2-5-16/Batangas
PTR No. 56789/12-22-15/Batangas

MCLE Compliance No. 87000/ 03-25-16

Doc. No. 85
Page No. 3
Book No. 3
Series of 2016.