Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
City of Quezon, Branch 88

ED SHEERAN,
Plaintiff,

CIVIL CASE No. 12345

-versus-
FOR: Unlawful Detainer

BRUNO MARS,
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel

and unto this Honorable Court, most respectfully avers:

1. That the plaintiff, ED SHEERAN, is of legal age, Filipino

citizen, single, with residence and postal address at 123 Road 1,
Bagong Pag-asa, Quezon City;

2. That the defendant, BRUNO MARS, is of legal age, Filipino

citizen, single, with residence and postal address at 456 Ayala
Avenue, Makati City where they may be served with summons
and other court processes;

3. The plaintiff is the owner of a land over which an apartment

had been constructed located 789 Road 13,Bagong Pag-asa,
Quezon City;

4. By virtue of a contract of lease, the plaintiff leased unto the

defendant the aforesaid apartment for a consideration of
P5,000.00 a month as rental to be paid within the first ten (10)
days of each month starting November 3, 2011;

5. The defendant failed to pay the agreed rental for several

months starting June 1, 2016 up to the present;

6. On October 1, 2016, 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 A;
7. Despite said letter of demand which was repeated by oral
demands, the defendant failed and still refused to pay the agreed
amount of rentals and to vacated the apartment;
8. 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
P10,000.00.

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 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.

City of Quezon, January 15, 2017.

CABIGUEN & BADAJOS LAW OFFICE

Counsel for the Plaintiff
Unit 123, Victoria Tower I
Mindanao Avenue, Quezon City

By:
CAYEN CABIGUEN
IBP No. 987654;
01/20/2017- Quezon City
PTR No. 54321; 02/18/2017-
Quezon City
Roll No. 112083; 11/20/2010
MCLE No. 4-321; 02/08/17

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Quezon ) S.S.

I, ED SHEERAN, of legal age, Filipino citizen, single and

resident of 123, after Road 1, Bagong Pag-asa, Quezon City,
 having been duly sworn to in accord Nance 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. he 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 15th of January 2017, in the City of Quezon.

ED SHEERAN

SUBSCRIBED AND SWORN to before me this 15th day of

January, 2017, in the City of Quezon, affiant exhibiting to me his
Drivers License No. 88888 issued by the Land Transportation
Office on July 13, 2012 at the City of Manila.

ATTY. RESHYL BADAJOS

Notary Public
IBP No. 534585; 02/10/2017- Quezon City
PTR No. 64936; 02/10/2017-
Quezon City
Roll No. 061793; 07/13/2010
MCLE No. 5-321; 05/15/17
Doc. No. ________
Page No. _______
Book No. _______
Series of 2017.