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REPUBLIC OF THE PHILIPPINES

Province of Iloilo
______ MUNICIPAL CIRCUIT TRIAL COURT

IYA ANG y WHITEHOUSE


Plaintiff,

Civil Case No._______


-versus- For: Unlawful Detainer

WALLY GHANA y MAGHALIN


Defendant.
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COMPLAINT

Plaintiff, IYA ANG y WHITEHOUSE, thru the undersigned counsel,


respectfully avers to this Honorable Court that:

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


Brgy. Balibagan, Sta. Barbara, Iloilo while the defendant is also
of legal age, Filipino, single, and a resident of Brgy. Namocon,
Tigabuan, Iloilo where summons and court process may be
served;

2. Plaintiff is the owner of land over which a house had been


constructed located at Brgy. Aganan, Pavia, Iloilo hereto
attached as Annex “A”

3. By virtue of a contract of lease with a term of five (5) years,


the plaintiff leased unto the defendant the aforesaid house and
lot for a consideration of P25,000.00 a month as rental to be paid
within the first ten (10) days of each month starting February 1,
1916 hereto attached as Annex “B”;

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


months starting March 1, 1921 up to the present;

5. On June 1, 1923, the plaintiff sent a letter of demand to


vacate the house which was received by the defendant as
shown in the registry return receipt hereto attached as Annex
“C”;

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6. 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 vacate the house;

7. 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.

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 P25,000.00 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 Iloilo, September 24, 1923.

ATTY. ABBU GADDO


Notary Public
City and Province of Iloilo
Commission No. 8008 Valid Until December 31, 1924
IBP No.: 01234556 /June 7, 1922/Pasig City
Roll No.: 99999
MCLE Compliance No.: 8888/June 8, 1922
PTR No.: 2490959/June 9, 1922/ Pavia, Iloilo
TIN 111-211-711
Gaddo & Gadda Law Offices
Pavia, Iloilo

VERIFICATION AND CERTIFICATION


AGAINST FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES )


CITY OF ILOILO )

I, IYA ANG y WHITEHOUSE, under oath, depose and state that:

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


2. I have caused the preparation of the foregoing
Complaint;

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3. The allegations therein are true and correct based on
my personal knowledge and authentic records;

4. To the best of my knowledge, there are no other


pending petitions of the same nature before any court,
tribunal or quasi-judicial agency; and

5. Should I thereafter learn of any similar case pending


before any other court, tribunal or quasi-judicial agency, I
shall promptly notify this court within five (5) days from
discovery.

IYA W. ANG

SUBSCRIBED AND SWORN to before me in the City of Iloilo on


this 24th day of September, 1921, affiant exhibiting before me her
Driver’s License F03-2010-04567 issued in Iloilo City and valid until
December 27, 1922.

NOTARY PUBLIC

ATTY. ABBU GADDO


Notary Public
City and Province of Iloilo
Commission No. 8008 Valid Until December 31, 1924
IBP No.: 01234556 /June 7, 1922/Pasig City
Roll No.: 99999
MCLE Compliance No.: 8888/June 8, 1922
PTR No.: 2490959/June 9, 1922/ Pavia, Iloilo
TIN 111-211-711
Gaddo & Gadda Law Offices
Pavia, Iloilo

Doc. No. ;
Page No. ;
Book No. ;
Series of 1921.