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Complaint Sample

Republic of the Philippines


Municipal Trial Court
Branch 5
Baguio City

Mr. Uzumaki Naruto, plaintiff


Accompanied by his Attorney in fact,
Atty. Poging Attorney

Civil Case No. 2


for:Unlawful Detainer

-versusMr. Uchiha Sasuke, Defendant


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

COMPLAINT

COMES NOW, the plaintiff together with the undersigned counsel to this most honorable court,
MOST RESPECTFULLY STATES THAT;
1.
2.

3.
4.
5.
6.
7.

8.
9.
10.

The Plaintiff is of legal age, married and a resident of Puguis, La Trinidad Benguet. The Defendant is likewise of legal
age, married and temporary residing at Petersville Subdivision, Baguio City.
The Plaintiff is the owner of the two-storey house unit located at the Petersville Subdivision, Baguio City, and having
the residential address of PV 123 as evidenced by pertinent documents like tax declaration and deed of sale. (
EXHIBIT A )
The Defendant is the lessee of the house unit that is owned by the Plaintiff as evidenced by the written contract of
lease that both parties signed. (Exhibit B)
The Plaintiff and the Defendant came up with a written agreement of Lease on June 26, 2007, which they both
agreed upon and was duly signed by the two parties as shown in their contract of lease. (Exhibit B)
Item No. 16 of the contract which the defendant signed expressly provides that he will only be occupying the property
for one (1) year, after which, he will vacate the house when that term expires. (Exhibit B)
The contract also provides that the defendant should also take care of the property and its premises with the utmost
diligence.
On June 28, 2008, the plaintiff, after returning from Japan, 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.
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.
On August 20, 2008, after continuous demands, the defendant constantly refuses to vacate the house unit and even
invited relatives to stay with him.
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.
th

Baguio City, Philippines, this 28 day of September 2008.

Poging Attorney
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: Manila
Rm. 4 2/F Baguio Boating Center
180 Burnham Lake, Baguio City

VERIFICATION AND CERTIFICATION


I, Mr. Uzumaki Naruto, of Legal age, married, Filipino Citizen and a resident of Puguis, La Trinidad Benguet, 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.
Uzumaki Naruto
Complainant
th

In witness thereof, I, Mr. Poging Attorney, counsel of the plaintiff, have herunto set my hand this 29 of September at
Baguio City.

Poging Attorney
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: Manila
Rm. 4 2/F Baguio Boating Center
180 Burnham Lake, Baguio City