Republic of the Philippines

MUNICIPAL TRIAL COURT

9th Judicial Division
Kumagko, Tinudlo del Sur
GLAIZA NAGNOLIS-KHUN
Plaintiff,
- Vs.

CIVIL CASE NO. 1234

FOR: Unlawful Detainer

MARIA EVELYN E. SIOV AND

VENUS E. SIOV
Defendants.
X------------------------------------------X

COMPLAINT
Plaintiff, through counsel and this Honorable Court respectfully alleges:
THE PARTIES
1. Plaintiff GLAIZZA NAGNOLIS-KHUN is of legal age, single, Filipino and a
resident of Barangay Kumingking, Kumagko, Tinudlo del Sur where she may be
reached by summons. A businesswoman, owner and operator of Home Sweet
Home Apartment;
2. Defendants MARIA EVELYN E. SIOV AND VENUS E. SIOV are sisters, of legal
age, single, Filipinos and all residents of Barangay Tinola, Manok-maniac, Tinudlo
del Norte where summons may be served to them;
PRELIMINARY STATEMENTS
3. The plaintiff in this case owns a parcel of land where an apartment has been
constructed, situated at Barangay Poblacion, Kumagko, Tinudlo del Sur;
4. Herein defendants were then occupants of one of the units of the said building.
5. By virtue of contract of lease, plaintiff leased the one of the units (Unit 123) of the
aforesaid property for a consideration of Six Thousand (6,000.00Php) as a monthly
rental which is to be paid within the first fifteen (15) days of the month that would
start on June 15, 2013, attached as Annex A;
6. However, defendants started to fail said obligation in the month of May 2014 up to
the present;
7. Consequently, plaintiff sent a letter demanding them to vacate the said unit by
September 1, 2014. Such letter was received by one of the defendants, Venus E.
Siov as shown in the registry return receipt hereto attached as Annex B;

8. Despite of the said notice and oral demands to vacate, defendants never paid the
amount due for the monthly rental and even refused to leave the said unit;
9. Thus, plaintiff compelled to file this complaint, including the costs of availing
services of the undersigned counsel for a total amount of Ten Thousand
(10,000Php).
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 P6, 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.
Kumagko, Tinudlo del Sur, January 15, 2015.
GETUTUA, DEMETRIA AND VIOS LAW OFFICE
Counsel for the Plaintiff
Unit 123, Kidapawan Tower 1
Poblacion,Kumagko, Tinudlo del Sur
By:
IVY MAE VIOS-GETUTUA
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Alapaap
PTR No. 87654/12-22-11/Alapaap

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )
City of Manila
) S.S.

I, GLAIZZA NAGNOLIS-KHUN is of legal age, single, Filipino and a resident of

Barangay Kumingking, Kumagko, Tinudlo del Sur having been duly sworn to in accord
Nance with law do hereby depose and say:
1.
2.
3.
4.

5.

6.

That I am the plaintiff in the above-entitled case;

That I have caused the preparation of the foregoing complaint and have read the
allegations contained therein;
The allegations in the said complaint are true and correct of my own knowledge
and authentic records;
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;
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;
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 15th of
January 2015 in Kumagko,Tinudlo del Sur.
GLAIZA NAGNOLIS-KHUN
Affiant
SUBSCRIBED AND SWORN to before me this 15th day of January 2015, in
Kumagko, Tinudlo del Sur, affiant exhibiting to me his Drivers License No. 12345
issued by the Land Transportation Office on April 8, 2014 at Kumagko, Tinudlo del Sur.
ATTY. ANDROMEDA VALDEZ
Notary Public
My Commission Expires Dec. 31, 2015
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Alapaap
PTR No. 87654/12-22-11/Alapaap
Doc. No. ________
Page No. _______
Book No. _______
Series of 2015