Group 5

Regional Trial Court

National Capital Judicial Region
Metropolitan Trial Court
Quezon City, Branch 33
ABC COMPANY,
Plaintiff,
Civil Case No. 012785
For: Ejectment
- versus -

Jose Alva Alvarez,

Defendant,

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

COMPLAINT
COMES NOW the PLAINTIFF by the undersigned counsel, and unto his Honorable Court,
respectfully alleges:
1.
That the Plaintiff is a domestic corporation with business address at 123 Don Ysidro, RBM
Compound, Quezon City, Metro Manila; while the Defendant is a Filipino, of legal age, single and
currently resident of 124 Don Ysidro, RBM Compound, Quezon City, Metro Manila, where he may be
served with summons and other pertinent processes.
2.
That the Plaintiff owns that property located at 124 Don Ysidro, RBM Compound, Quezon City ,
Metro Manila, which it leased to the Defendant under the terms and conditions stated in the Contract of
Lease dated 1 January 2012, which contract expires on 31 December 2013. A copy of the contract is
attached as ANNEX A.
3.
That upon expiration of the contract, the Plaintiff informed the Defendant of its intention not to
renew the lease as it would use the property for its business expansion; the Plaintiff then asked the
Defendant to vacate the premised. A copy of plaintiffs letter to defendant is attached as Annex B.
4.
That despite demand duly made and received, the Defendant has refused to vacate the premised
and continues to occupy the property without the Plaintiffs consent. Resort to the Barangay conciliation
system proved useless as the Defendant refused to appear before the Lupong Tagapamayapa. A
Certification to File Action is attached
as Annex C.
5.
That the Defendants act of dispossession has caused the Plaintiff to suffer material injury because
the Plaintiffs business expansion plans could not be implemented despite the arrival of machineries
specifically leased for this purpose at the rental rate of
Php 25,000.00 per month. The Defendants continued occupation of the premises has also forced the
Plaintiff to sue and to incur legal expenses amounting to Fifty Thousand Pesos
(Php 50,000.00).
WHEREFORE, the Plaintiff respectfully prays for judgment in its favor by ordering the Defendant to
vacate the property and peacefully turn over possession and to compensate Php 175,000.00 representing
rentals on the machineries for seven (7) months and Fifty Thousand Pesos (Php 50,000.00) for Attorneys
fees.
Other just and equitable reliefs are also prayed for.

Quezon City, Metro Manila ; 19 October 2014

(Sgd.) ATTY. REX B. MENDOZA
Counsel for Plaintiff
Malate, Manila , Philippines
VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING
I, Manleo Plata Custodio, Filipino, of legal age, do hereby state that: I am the Chief Executive officer
of ABC Company and in such capacity, caused this Complaint to be prepared; I have read its contents
and affirm that they are true and correct to the best of my own personal knowledge; I hereby certify that
there is no other commenced or pending before any court involving the same parties and the same issues
and that, should I learn of such a case, I shall notify the court with five (5) days from my notice.
th
IN WITNESS WHEREOF, I have hereunto set my hand on this 19 day of October, 2014.
(Sgd.) MANLEO PLATA CUSTODIO
Affiant
th

SUBSCRIBED and sworn to before me in the City of Manila on this 19 day of October, 2014, affiant
rd
exhibiting his Community Tax Certificates No. 05091946 issued at Quezon City , Philippines on 3 day of
January, 2014.
NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2014.
Arellano University School of Law
Legal Writing
Group 5

Regional Trial Court

National Capital Judicial Region
Metropolitan Trial Court
Quezon City, Branch 33
JOVELE CORTO CARABLE,
Plaintiff,
Civil Case No. 050946
For: Breach of Contract
- versus -

JENNIFER KATHLEEN ENDOZO VERGARA,

Defendant,

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

COMPLAINT
COMES NOW the PLAINTIFF by the undersigned counsel, and unto his Honorable Court,
respectfully alleges:
1.
That the Plaintiff herein, Jovele Corto Carable, Filipino, of legal age and currently resides at 555
Rafael Lubis Street, Cubao, Quezon City, Metro Manila; while the Defendant herein, Jennifer Kathleen
Endozo Vergara, Filipino, of legal age, and has a principal place of business at 143 Main Street, Cubao,
Quezon City, Metro Manila. The Defendant is engage in the business of manufacturing automobiles.
2.
That the Plaintiffs desired to have a unique automobiles manufactured pursuant to a design
prepared by him. The Plaintiff and the Defendant discussed the formers needs and specifications for this
project.
3.
That on 01 March 2013, the Plaintiff and the Defendant entered into a written agreement. Pursuant
thereto, the Plaintiff agreed to pay the sum of Php 2,000,000.00 for the automobiles. The Plaintiff was
obligated to make a down payment of Php 1,000,000.00 on or before 01 April 2013, with the balance to
be due upon delivery of the submarine. The Defendant agreed to manufacture the automobiles in
accordance with the Plaintiffs design for the aforesaid price and to complete the work and deliver the
automobiles to a fixed place on or before 01 October 2013.
4.
That on 15 March 2013, the Plaintiff delivered to the Defendant a certified check in the sum of Php
1,000,000.00, which latter cashed.
5.
That the Defendant failed to deliver the submarine on or before 01 October 2013, as agreed. The
Plaintiff made numerous phone calls and sent several letters to the Defendant about the contract, but
received no response.
6.
That by reason of the facts and circumstances stated above, the alleged failure was a dereliction
of the Defendants breach of contract caused the Plaintiff irreparable harm for which it should be
compensated and for which the Defendants should be punished for failing to deliver the automobiles as
agreed.
7.
That as a proximate result of the Defendants breach of contract, the Plaintiff has been suffered
compensatory damages in the sum of Php 1,000,000.00 to be proven at trial.
WHEREFORE, the Plaintiff respectfully prays for judgment in its favor by ordering defendant in the sum of
Php 1,000,000.00, plus interest from 01 October 2013, costs and disbursements, together with any other
relief the Court finds to be just and proper.
Quezon City ; 19 October 2014
(Sgd.) ATTY. REX B. MENDOZA
Counsel for Plaintiff
Malate, Manila , Philippines
VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING
I, Jovele Corto Carable, of legal age, do hereby state that: I am the Plaintiff in the above-entitled
action, and in such capacity, caused this Complaint to be prepared; I have read its contents, except as to
matters therein stated to be alleged on information and belief, and affirm that they are true and correct to
the best of my own personal knowledge,; I hereby certify that there is no other commenced or pending
before any court involving the same parties and the same issue and that, should I learn of such a case, I
shall notify the court with five (5) days from my notice.
th
IN WITNESS WHEREOF, I have hereunto set my hand on this 19 day of October, 2014.
(Sgd.) JOVELE CORTO CARABLE
Affiant
th

SUBSCRIBED and sworn to before me in the City of Manila on this 19 day of October, 2014, affiant
rd
exhibiting his Community Tax Certificates No. 05091946 issued at Quezon City , Philippines on 3 day of
January, 2014.
NOTARY PUBLIC

Doc. No.
Page No.
Book No.
Series of 2014.

Thanks and regards,

Rex B. Mendoza
Accounts Management Group 3
Department of Loans and Credit
0917 - 510 - 4979

From:
"William C. Matias" <wcmatias@pandiman.com>
To:
Rose May Erazo <erazors@sss.gov.ph>, Nikki Dianne Erni <nikkidianneerni@yahoo.com>, "mendozarexb@hotmail.ph "
<mendozarexb@hotmail.ph >, "MendozaRE@bsp.gov.ph" <MendozaRE@bsp.gov.ph>, "lionight_jel@yahoo.com "
<lionight_jel@yahoo.com >, "wcmatias79@yahoo.com" <wcmatias79@yahoo.com>,
Date:
10/10/2014 11:40 AM
Subject:
LEGAL WRITING (FINAL) Topics Due ASAP: Sunday, 12th October 2014

Due ASAP, So sorry:

First Legal Document: AFFIDAVIT OF LOSS OF A PAWNSHOP TICKET
REPUBLIC OF THE PHILIPPINES )
MADDELA, QUIRINO
) S.S
AFFIDAVIT OF LOSS

I, VICE GANDA, of legal age, Filipino, single, presently residing at Poblacion Norte, Maddela, Quirino, after being
been duly sworn to in accordance with law do hereby depose and state the following:
1. That I am owner and pawner of an item described on the pawn ticket as one pair of earring yellow gold 21k and
one piece bracelet yellow gold 21k, 6.1grams modern amount of Php7,500, which I pawned at TAMBUNTING
PAWNSHOP Maddela, Quirino, with Pawnshop Ticket No. 3357 with loan date on October 22, 2013 and
maturity date on February 22, 2014,

2. That I kept the said pawn ticket inside my bag for safe keeping but unfortunately it was misplaced,
3. That the pawn ticket issued to me by TAMBUNTING PAWNSHOP was misplaced,
4. That despite of all efforts to find the pawn ticket, I still cannot locate it and consider it lost forever,
5. That I am executing this affidavit to attest the truth of all forgoing and to enable me to secure a duplicate or
substitute copy of ticket and/or redeem the item which I pawned.
IN WITNESS WHEREOF, I have affixed my signature this 22th day of February 2014 at Maddela, Quirino.
VICE GANDA
Affiant
SUBSCRIBED AND SWORN to before me this 22th day of February 2014, affiant having exhibited her
Community Tax Certificate No.________issued on ________ at Maddela, Quirino, Philippines.
Doc. No. ________
Page No. ________
Book No. _______
Series of 2014.
JHONG HILARIO
Notary Public
Maddela/Nagtipunan
PTR.No.0010983/01.03.14/Maddela
IBP No.753926/12.22.10/Quirino
Admin. Matter No.2009-2/Until Dec.31, 2014
Lawyers Roll No. 52289
MCLE Compliance No. 111-6090/11.11.09
Poblacion Norte, Maddela, Quirino