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Complaint for Unlawful Detainer

25th September 2012
Sample

REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT
City of Manila
Branch 1

KRUL ACOSTA,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Unlawful Detainer

MEGAN VITUG,
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable
Court, most respectfully avers:
1. That the plaintiff, KRUL ACOSTA, is of legal age, Filipino citizen, single, with residence
and postal address at 123 Benitez Street, Manila;
2. That the defendant, MEGAN VITUG, 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 rst
ten (10) days of each month starting November 3, 2011;
5. The defendant failed to pay the agreed rental for several months starting February 19,
2012 up to the present;
6. On May 3, 2012, 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. By reason of failure of the defendant to vacate the premises and to pay the unpaid
rentals, the plaintiff was compelled to le 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 P5,000.00 per month as compensation for the reasonable use of
the subject premises until they nally vacate the said premises;
3. To pay the plaintiff the cost of the suit.
City of Manila, September 24, 2012.

REYES, TOLENTINO AND CRUZ LAW OFFICE

Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Manila

By:
Louise Reyes
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Manila ) S.S.

I, KRUL ACOSTA, of legal age, Filipino citizen, single and resident of 123 Benitez Street,
Manila, after having been duly sworn to in accord Nance 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 led or is
pending, I hereby undertake to report that fact within ve (5) days therefrom to the court
or agency where the original pleading and sworn certication contemplated herein have
been led;
6. I executed this verication/certication 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 afxed my signature this 24th of September
2012, in the City of Manila.

KRUL ACOSTA

SUBSCRIBED AND SWORN to before me this _______ day of September, 2012, in the City
of Manila, afant exhibiting to me his Drivers License No. 12345 issued by the Land
Transportation Ofce on April 8, 2012 at the City of Manila.
 ATTY. NO CASE
Notary Public
My Commission Expires Dec. 31, 2012
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

Doc. No. ________

Page No. _______
Book No. _______
Series of 2012.

Posted 25th September 2012 by MRC

Labels: Forms in Civil Action, Legal Forms