Republic of the Philippines

OFFICE OF THE CITY PROSECUTOR

City of Manila

AAA BBB
Plaintiff

-versus- I.S. No. 123456

For: B.P. Blg 22

CCC DDD,
Respondent
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COMPLAINT

PLAINTIFF, by counsel, and unto this Honorable Court, most

respectfully avers:
1. That plaintiff is of legal age, Filipino, with residence and postal
address at 638 Mendiola St, San Miguel, Manila, Metro Manila;

2. That respondent is of legal age, Filipino, with residence and postal

address at 1001 San Rafael St, San Miguel, Manila, 1001 Metro
Manila;

3. That plaintiff is the absolute owner and lessor of that certain

apartment situated at the City of Manila and now leased and
occupied by the respondent;

4. That the respondent leases and occupies the said apartment from
January 1, 2017 until June 31, 2017 as agreed upon between the
plaintiff and the respondent in the lease contract executed on
January 1, 2017 under the express obligation to pay a monthly
rental of P 50,000.00; (Copy of Contract of Lease is hereto
attached as Annex “A”)

5. That the lease contract of the respondent for the occupation of the
building has been terminated on June 31, 2017 and has not been
renewed or extended;

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 6. That during the course of the respondent’s occupation of the said
apartment, respondent has failed to pay her rentals for the months
of March, April, , and May 2017;
7. That respondent has continued to occupy the said apartment
notwithstanding the fact that her contract of lease has been
terminated on June 31, 2017 thus depriving the plaintiff from
having the said apartment leased by other persons;

8. That several demands to vacate was made by plaintiff to

respondent, although orally, but respondent refused to vacate the
said apartment and return possession to the plaintiff;

9. That on July 15, 2017, plaintiff sent a letter to respondent as a last

and final demand for respondent to vacate plaintiff’s apartment;
(Copy of Demand Letter is hereto attached as Annex “B”)
10.That until now Respondent still refuse to vacate and restore
possession and pay his rentals during his occupation of the
apartment;

11.Thus, Respondent is unlawfully withholding possession of the

subject apartment from the plaintiff despite last and final demand,
to the damage and prejudice of the plaintiff;
12.That before filing of this complaint, the dispute has been referred
to the Lupong Tagamayapa but the parties failed to arrive at an
amicable settlement; (Certificate to File Action is hereto attached
as Annex “C”)

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that after due notice and hearing, judgment be rendered
in favor of Plaintiff:

1. For the restitution of the abovementioned apartment;

2. For the payment of ONE HUNDRED FIFTY THOUSAND (P

150,000.00) PHILIPPINE CURRENCY, representing the arrears
of rent now overdue.

3. To pay the costs for this suit.

Other reliefs just and equitable under the premises are likewise prayed
for.

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City of Manila, Philippines, July 25, 2017.

CAR LAW OFFICE

Counsel for Plaintiff
Unit 123, Blue Building,
Ayala Avenue, Makati City

By:

Atty. Christian Roque

PTR No: 0123456
IBP No.:123456
Roll No.: 123456