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Republic of the Philippines REGIONAL TRIAL COURT First Judicial Region Branch 5 Roxas City

Mr. Michael Golero, Accompanied by his Attorney in fact, Atty. Jerico Roxas Plaintiff, -versusMr. Jefferson Almalbis, Defendant, x---------------------------------------------------------x

Civil Case No. 2 for:Unlawful Detainer


COMES NOW, defendant through the undersign counsel and unto this honourable court, most respectfully states: 1. That defendant admit the allegations stated in paragraphs 1, 2 and 8 of the complaint; 2. That defendant denies paragraph 3 of the complaint for the reason that the latter is not a lessee of said property, but as the owner thereof; 3. That the defendant denies paragraph 4 of the complaint for it was a deed of sale which they both agreed upon, not a contract of lease. 4. That defendant denies paragraphs 5, 6, 7 and 9 of the complaint for the latter has no knowledge as to the truth and fact of the same; 5. 87777777777777777777777777777777777777777777777777777777777777777777777777777777777 777777777777777777777777777777777777 6. The contract also provides that the defendant should also take care of the property and its premises with the utmost diligence. 7. On June 28, 2012, the plaintiff, after returning from Manila, was surprised to discover that the defendant did not vacate the property as he expected. Worse, he installed a sari -sari store in the original building structure of the house unit. 8. The plaintiff confronted the defendant about it but the defendant claimed that it was a DEED OF SALE which they signed and not a CONTRACT OF LEASE and therefore, the defendant is the new owner of the house unit. 9. On August 20, 2012, after continuous demands, the defendant constantly refuses to vacate the house unit and even invited relatives to stay with him.

10. The defendant willfully and maliciously violated the agreement which they mutually agreed upon, and which the defendant signed.

PRAYER WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that judgement be rendered in favor of the plaintiff and that after judgement; a. b. The defendant shall vacate the house unit owned by the plaintiff. The defendant shall be ordered to pay P 120, 000 for the Attorneys Fees. Such other reliefs and remedies under the premises are likewise prayed for. Roxas City, Philippines, this 28 day of September 2012.

Jerico Roxas Counsel for the Plaintiff PTR No. 18909595:1-04-07:R.C. IBP No, 693095:1-04-07:R.C. Roll No. 42481:5-10-97: Roxas Rm. 4 2/F Golden gate Bldg. 180 Tiza St., Roxas City

VERIFICATION AND CERTIFICATION I, Mr. Michael Golero, of Legal age, married, Filipino Citizen and a resident of Cabog-cabog, Pres. Roxas Capiz, after being sworn according to law, hereby depose and state that; 1. 2. I am the Complainant in this proceeding. I have read and understood the filed complaint and allegations therein. Michael Golero Complainant In witness thereof, I, Mr. Jerico Roxas, counsel of the plaintiff, have herunto set my hand this 29 of September at Roxas City.

Jerico Roxas Counsel for the Plaintiff

PTR No. 18909595:1-04-07:B.C. IBP No, 693095:1-04-07:B.C. Roll No. 42481:5-10-97: Roxas Rm. 4 2/F Golden gate bldg. 180 Tiza St., Roxas City