REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

7TH JUDICIAL REGION
CITY OF CEBU
Branch ___

CONCHITA M. TABASA,
Plaintiff,
CIVIL CASE No. ___________
-versus- FOR: Unlawful Detainer

RABILYN ENTERO and

NIKKI ENTERO,
Defendants.
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COMPLAINT

Plaintiff, through the undersigned counsel and unto this

Honorable Court, most respectfully avers:

1. Plaintiff, CONCHITA M. TABASA, is of legal age, Filipino

citizen, with residence and postal address at Sandayong,
Guadalupe, Cebu City;

2. Defendants, RABILYN ENTERO and NIKKI ENTERO, are

both of legal ages, Filipinos, with residence and postal address
at Sandayong, Guadalupe, Cebu City, where they may be
served with summons and other court processes;

3. The plaintiff is the owner of a parcel land located at

Sandayong, Guadalupe, Cebu City;

4. Plaintiff leased unto the defendant a portion of the aforesaid

land for a consideration of P500.00 a month as rental;

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

months starting May 2016 up to the present;

6. Repeated oral demands were made upon Defendants by

Plaintiff’s representative, Lucita M. Tabasa, to update
their rental arrearages. However, Defendants failed and
refused to pay to the damage and prejudice of Plaintiff;

7. Plaintiff referred this matter to the Lupong Tagapamayapa of

Barangay Guadalupe. However, Defendants in abject bad faith
and without justifiable reasons, refused to appear in the said
hearings before the Lupon. Thus, a Certificate to File Action

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 was issued by the Lupong Tagapamayapa. Attached hereto as
Annex “A” is a copy of the said Certificate to File Action;

8. On ___________, 2017, the Plaintiff sent a letter of Demand

to Vacate the land which was received by the Defendants on
_________. A copy of the receiving copy of the said Demand
Letter is hereto attached as Annex “B”; (A copy of the registry
return receipt is hereto attached as Annex “B”;)

9. Despite the said letter of demand which was repeated by oral

demands, the defendant failed and still refused to pay the
rentals in arrears and to vacate the subject land leased by
them;

10. In light of Defendants adamant refusal to pay and vacate the

leased premises, Plaintiff was constrained to institute this
case, incurring in the process, obligations for litigation
expenses and attorney’s fees in the amount of Php
_____________.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed unto this Honorable Court that judgment be rendered
ordering the defendant:

1. To vacate the subject premises leased by them;

2. To pay the monthly sum of Php 500.00 beginning with the

month of May 2016, with interest thereon at the legal rate
until fully paid until the Defendants vacate the premises;

3. To pay the plaintiff the cost of the suit.

Plaintiff further prays for such other reliefs as this Honorable

Court may deem just and equitable.

Mandaue City for Cebu City, Philippines, March 6, 2017.

ATTY. ANTONIO C. ASENIERO

Counsel for the Plaintiff
2/F Cityscape Hotel
F. Cabahug Street, Ayala Access Road
Subangdaku, Mandaue City
Tel. No. 420-9498
Cellphone No. 0922-8398463
antonio.aseniero@gmail.com
Roll of Attorneys No. 58948

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 IBP No. 1065109, 1/10/17, Cebu
PTR No. -, -/-/-, Cebu City
MCLE Compliance No. V-0013335, 1-27-16, Pasig City

VERIFICATION and
CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines)

City of Cebu ) S.S.

I, CONCHITA M. TABASA, of legal age, Filipino and resident of

Sandayong, Guadalupe, Cebu City, after having been duly sworn to in
accordance with law do hereby depose and say that:

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

2. I have caused the preparation of the foregoing complaint and

have read the allegations contained therein;

3. The allegations in the said complaint are true and correct of my

own knowledge and/or based on 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.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this _____ of ________ 2017, in the City of Cebu.

CONCHITA M. TABASA

SUBSCRIBED AND SWORN to before me this _______ day of

________ 2017, in the City of Cebu, affiant exhibiting to me her
__________________.

Doc. No._____;
Page No._____;
Book No. ____;
Series of 2017.

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