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Genesaret P.

Camlas
Legal Forms: Complaints and Answers
November 18, 2018

PACINA AGOONG,
Plaintiff,
CIVIL CASE No. 000001
-versus- FOR: Unlawful
Detainer
LAUREN PALANA,
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel


and unto this Honorable Court, most respectfully avers:

1. That the plaintiff, PACINA AGOONG, is of legal age, Filipino citizen,


single, with residence and postal address at 555 New Lucban,
Baguio City;
2. That the defendant, LAUREN PALANA, is of legal age, Filipino citizen,
single, with residence and postal address at 777 Navy Base, Baguio
City, 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 888 Bakakeng, Baguio City;
4. By virtue of a contract of lease, the plaintiff leased unto the
defendant the aforesaid apartment for a consideration of P10,000.00
a month as rental to be paid within the first ten (10) days of each
month starting June 5, 2017;
5. The defendant failed to pay the agreed rental for several months
starting March 6, 2018 up to the present;
6. On May 5, 2018, 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”;
Genesaret P. Camlas
Legal Forms: Complaints and Answers
November 18, 2018
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 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 P10,000.00 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 Baguio, November 17, 2018.

WANASON-KUBARNO LAW OFFICE


Counsel for the Plaintiff
Unit 123, FelizLoy Building
Session Road, Baguio City

By:
SANDRA B. WANASON
Roll of Attorney No. 1092974
IBP No. 12345/2-5-18/Baguio City
PTR No. 87654/5-22-17/Baguio City
Genesaret P. Camlas
Legal Forms: Complaints and Answers
November 18, 2018
VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )


City of Baguio ) S.S.

I, PACINA AGOONG, of legal age, Filipino citizen, single and


resident of 555 New Lucban, Baguio City, 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 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 17th


of November 2018, in the City of Baguio.

PACINA AGOONG
Genesaret P. Camlas
Legal Forms: Complaints and Answers
November 18, 2018

SUBSCRIBED AND SWORN to before me this 17th day of


November 2018, in the City of Baguio, affiant exhibiting to me his
Driver’s License No. 098765 issued by the Land Transportation Office
on March 9, 2017 at the City of Baguio.