REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

CITY OF MALAYBALAY
BRANCH 9

MERIAM PIYA VILLAR

Plaintiff,
CIVIL CASE No. 82843
FOR: Unlawful Detainer

-versusTEOFISTO ENRILE SOTTO

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

COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1.
2.

3.
4.

5.

6.
7.

8.
9.

That the plaintiff, MERIAM PIYA VILLAR, is of legal age, Filipino citizen, single,
with residence and postal address at Claro M. Recto Street, Malaybalay City;
That the defendant, TEOFISTO ENRILE SOTTO, is of legal age, Filipino citizen,
single, with residence and postal address at Casisang, Malaybalay City, where may be
served with summons and other court processes therein by this Honorable Court;
The plaintiff is the legal owner of a land over which an apartment had been
constructed located 654 San Pedro Street, Manila;
By virtue of a contract of lease, the plaintiff leased unto the defendant the
aforesaid apartment for a consideration of P8,000.00 a month as rental to be paid within
the 15th day of the month starting April 15, 2012;
Such Contract of Lease as Annex A as attached thereto stipulates that any
violation in the forgoing provisions shall subject the contract to be terminated and the
lessee to vacate the premises;
The defendant failed to pay the agreed rental for eight months starting May 15,
2013 up to the present;
On December 10, 2013, 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 B;
Despite the said letter of demand which was followed up by oral demands, the
defendant failed to pay the agreed amount of rentals and to vacate the apartment;
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.

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;
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 finally vacate the said premises;
3. To pay the plaintiff the cost of the suit
Such other reliefs and remedies under the premises are likewise prayed for.
Malaybalay City, Philippines, this 28th day of February 2014.

CHRISTIE DELUTE LIM

Counsel for the Plaintiff
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 Malaybalay
) S.S.

I MERIAM PIYA VILLAR, of legal age, Filipino citizen, single and resident of Claro
M. Recto Street, Malaybalay City, 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 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 28th of
February 2014, in the City of Malaybalay.

MERIAM PIYA VILLAR

Plaintiff

SUBSCRIBED AND SWORN to before me this 1st day of March, 2014, in the City
of Malaybalay, affiant exhibiting to me his Drivers License No. 855421 issued by the
Land Transportation Office on April 8, 2013 at the City of Malaybalay

CHRISTIE DELUTE LIM

Counsel for the Plaintiff
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

Doc. No. ________

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