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REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT


BRANCH 6, MAKATI CITY

JUANA,
Plaintiff,

-VERSUS- CIVIL CASE NO. ____


FOR: EJECTMENT
MARIO,
Defendant.
x------------------------------------x

COMPLAINT

COMES NOW the plaintiff by the undersigned counsel and unto this
Honorable Court, respectfully avers:

1. That plaintiff is of legal age, Filipino, single, and a resident of


Apartment unit 25-A, Lacson St., Makati City;

2. That plaintiff is the absolute owner and lessor of the certain apartment
building situated at Lacson St., Makati City;

3. That defendant, Mario, is a tenant of said apartment building, and is


occupying Apartment Unit 25–C, under the express obligation of
paying a rent in the amount of Php 4,285 per month, payable on or
before the 5th of each month; Attached as Annex “A” is the contract
between plaintiff and defendant.

4. That plaintiff has several times demanded of the defendant to vacate


the said apartment unit and to pay the sum of Php 30,000 for back
rentals, the last demand having been made to him personally and in
writing. Attached hereto as Annex “B” is the last demand letter sent to
defendant

5. That before resorting to legal action, plaintiff and defendant went to


the Barangay for Conciliation but such didn’t go well. Hence attached
hereto as Annex “C” is the Certificate to File Action issued certifying
that parties failing to reconcile before the Barangay may resort to
legal action.

6. That plaintiff then sought legal action against herein defendant. She is
demanding from the plaintiff the restitution of the property as well as
the payment of arrears of rent with legal interest.
WHEREFORE, it is respectfully prayed that, after due hearing, judgment
be rendered in favor of the plaintiff:

1. For the restitution of the above-mentioned premises;

2. For the payment of Php 30,000, representing the arears of rent now
overdue, with legal interest from the filing of this complaint, and cost
of suit.

Such other relief as may be just and equitable under the premises are
likewise prayed for.

Bacolod City, February 11, 2015.

ANNA CARMELA G. VIRTUCIO


Counsel for PLAINTIFF
Valero Street, Brgy. Salcedo, Makati City
P.T.R. No. 12567* Makati City * January 11, 2015
I.B.P No. 78655* Makati City * January 10, 2015
MCLE No.12347* Makati City * January 10, 2012
Roll No. 56734
VERIFICATION AND CERTIFICATION OF NON-FORUM
SHOPPING

I, Juana, of legal age, Filipino, single, and a resident of Apartment


Unit 25-A, Lacson St., Bacolod City, under oath declare that:

1. I am the plaintiff in the above-entitled case;

2. I have caused the preparation of this complaint;

3. I have read it and its contents are true and correct of my personal
knowledge and/ or based on authentic records.

4. I have not earlier commenced a similar action against the defendant


for the same cause with any other court, tribunal or quasi-judicial agency;
and if I should learn that a similar action or proceeding has been filed or is
pending before any other court, tribunal or quasi-judicial agency, I hereby
undertake to notify this Honorable Court within five (5) days from such
notice.

JUANA
Affiant
Drivers’ License No. F01-48-011415

JURAT

SUBSCRIBED AND SWORN to before me this 21st day of March


2018 at Bacolod City, Negros Occidental. Affiant presented to me her
Drivers’ License with License No. F01-48-011415 expiring on 2020-11-15.

JARVY M. PINONGAN
Notary Public
Commission Serial No.______
Notary Public for Bacolod City
Goldcrest Village, Brgy. Bata, Bacolod City
P.T.R. No. ___ Bacolod City 02/11/2015
I.B.P. No._____ Bacolod City 02/11/2015
MCLE No.____Bacolod City 02/11/ 2015
Roll No. _____

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