REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
MANILA, BRANCH 20

MICHAEL KASERA,
Plaintiff,
Civil Case No. ______________
-versus- For: Unlawful Detainer
(Ejectment Case )

DENNIS MANUNUBA,
Defendant,
x--------------------------------x

COMPLAINT

PLAINTIFF, by undersigned counsel, unto this

Honorable Court, respectfully avers that:

1. The plaintiff is of legal age, Filipino, and presently

residing at No.255 Makulit St.,Brgy Plainview,
Mandaluyong City where he may be served with
notices and other court processes.

2. The defendant is also of legal age, Filipino and

presently residing at 333 Pureza St., Brgy 456, Sta
Mesa Manila where he may be served with summons
and other court processes.

3. The plaintiff is the absolute owner and lessor of the

above certain residential house located at 333
Pureza St., Brgy 456, Sta Mesa Manila and now being
leased and occupied by the defendant.

4. The defendant leases and occupies said residential

house under the express obligation of paying a rent
of SEVEN THOUSAND ( Php 7,000.00) PESOS a
month, payable in advance within the first (5) days of
every month. A copy of notarized lease contract is
hereby attached hereof as Annex “A” and made an
integral part of this complaint.

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 5. Defendant has not paid his rental obligation for said
residential house for the month of July, August and
September 2016 despite demand to pay either orally
and written. A copy of two (2) demand letters to pay
are hereby attached and marked as Annex “B” and
“B-1” thus made integral part of this complaint.

6. After deliberate refusal to pay said rental obligation

under the lease agreement, the plaintiff brought the
dispute before the Lupon Tagapamayapa of Barangay
456 of Sta Mesa Manila but the defendant-lessee did
not appear thereto despite due notices. A copy of
Certificate to File Action duly signed by the Chairman
is hereby attached hereof as Annex “C” and made
an integral part of this complaint.

7. Nevertheless, the plaintiff sends final demand to

vacate the premises within five (5) days upon receipt
thereof but the defendant has wantonly, whimsically
and capriciously disregarded and unheeded the
same. A copy of demand to demand letter to vacate
premises is hereby attached hereof as Annex “D”
and made an integral part of this complaint.

PRAYER

WHEREFORE, It is respectfully prayed that after

notice and hearing on the merits, judgment be rendered in
favor of the plaintiff as follows:

a.) Restitution of physical possession of the above

mentioned residential house in issue;

b.) For the payment of TWENTY EIGHT THOUSAND

( Php 28,000.00) PESOS representing the
arrears of rent payments overdue, plus FIVE
THOUSAND SEVEN HUNDRED (Php 5,000.00)
PESOS as interest, late fees and cost of this
suit;and

c.) For attorney’s fees in the amount of TWENTY

THOUSAND (Php20,000.00) PESOS

d.) Granting the respondent such offer relief as may

be just and equitable under the premises.

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 Manila City, Philippines, on this 12 th day of October,
2016.

AVELIN & ASSOCIATES LAW

FIRM
Ermita Building Center, United Nation
Avenue, Corner Taft Avenue Ermita
Manila
(02) 543-75-86

BY:

PATRICK MARZ AVELIN

Counsel for the Plaintiff
Attorney Roll No. 65434
PTR No. 8732/ 06-15-2015
IBP No. 46532/06-12-2014
MCLE Compliance No. 76432 -RSM

(ATTACHED VERIFICATION AND

CERTIFICATION AGAINST FORUM
SHOPPING)