Solitaryrebel.blogspot.com-Complaint for Unlawful Detainer Sample

Com omplaint plaint for Unlaw Unlawfu full Deta Det ainer Sa Sam mple solitaryrebel.blogspot.com /2012/ /2012/09/c 09/complai omplaintnt- f or- unla unlawf wf ul-detainer-s am ample. ple.html html

REPUBLIC REPU BLIC OF T HE PHILI PHILI PP PPII NE NES S METROPOLITAN TRIAL COURT City of Man Manila ila Branch 1 KRUL ACOSTA,   Plaintiff, CI VIL CASE No. 98 9876 765 5 FOR:: Un FOR Unlawful lawful Detainer 

- versusMEGA ME GAN N VIT UG,

Def endant.

x-----------------------------------x COMPLAINT COMES NOW NOW,, the plaintif f , through t he un unders dersigned igned counsel counsel and unto unto this Honorab Honorable le Court, Cou rt, most respectf ully avers: 1. T hat the t he plaintif plaintif f , KRUL KRUL ACOSTA ACOSTA,, is of legal age, Filipin Filipino o citiz en, single, single, with with residence and and post al address at 12 123 3 Beni Benitez tez Street Street,, Manila; Manila; 2. T hat the def endan endant, t, MEGA MEGAN N VIT VIT UG UG,, is of legal age, Filipin Filipino o citiz en, sin single, gle, with with residence and postal posta l address at 45 456 6 Modest Modest o Street , Manila, Manila, where where t hey may be served wi with th summon summons s and ot her court court processes processes;; 3. T he plain plaintif tif f is the owner owner of a land land over which which an apart men mentt had been const constructed ructed located 654 San Pedro Street, Manila; 4. By virtue virtue of a contract contract of lease, the plain plaintif tif f leased un unto t he def en endan dantt t he af oresaid apart men mentt f or a consideration of P5 P5,0 ,000 00.0 .00 0 a month month as  rental t o be paid pa id within within the f irst te ten n (10) (10) days of each month month st art artin ing g November 3, 201 2011; 1; 5. T he def endan endantt f ailed to pay the agreed renta rentall f or several months months st starting arting February February 19,, 2012 19 2012 up to t he present; prese nt; 6. On May May 3, 3, 201 2012, 2, the plaintif plaintif f sent a lett er of deman demand d to vacate vaca te t he apart men mentt which which was received by t he def endan endantt as a s shown shown in in the registry ret urn receipt hereto attt ached as Annex at Annex “A” “ A”;; 7. Despite said lett er of deman demand d which which was repeated by oral demands, demands, the def endan endantt f aile ailed d and still refused to pay the agreed amou amoun nt of ren rentals tals and to vacat ed the apartment;

8. By reason of f ailure of the def endant t o 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 respectf ully prayed unto this Honorable Court that, after hearing, judgment be rendered ordering the defendant: 1. To vacat e the subject premises; 2. To pay the amount of P5,000.00 per month as compensation f or the reasonable use of the subject premises until they finally vacate the said premises; 3. To pay the plaintif f the cost of t he suit. City of Manila, Sept ember 24, 2012. REYES, TOLENTINO AND CRUZ LAW OFFICE Counsel f or the Plaintif f  Unit 123, Victoria Tower I Taf t Avenue, Manila By: Louise Reyes Roll of Att orney No. 98765 IBP No. 12345/2-5-12/Manila PTR No. 87654/12-22-11/Manila VERIFICATION/CERTIFICATION OF FORUM SHOPPING Republic of the Philippines ) City of Manila ) S.S. I, KRUL ACOSTA, of legal age, Filipino citizen, single and resident of 123 Benitez Street, Manila, after having been duly sworn to in accord Nance with law do hereby depose and say: 1. That I am the plaintif f in the above-entitled case; 2. That I have caused the preparat ion of the f oregoing complaint and have read the allegations contained therein; 3. The allegations in the said complaint are true and correct of my own knowledge and authentic records; 4. I hereby certif y 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 thereaf ter that a similar action or proceeding has been f iled or  is pending, I hereby undertake t o report t hat f act within five (5) days therefrom to the court or agency where t he original pleading and sworn certif ication contemplated herein have been f iled; 6. I executed this verif ication/certif ication to att est to t he truth of t he f oregoing f acts and to comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court. IN WIT NESS WHEREOF, I have hereunto af f ixed my signature this 24th of  September 2012, in the City of Manila. KRUL ACOSTA SUBSCRIBED AND SWORN to bef ore me this _______ day of September, 2012, in the Cit y of Manila, af f iant exhibiting to me his Driver’s License No. 12345 issued by the Land Transportat ion Of f ice on April 8, 2012 at t he City of Manila. ATTY. NO CASE Notary Public My Commission Expires Dec. 31, 2012 Roll of Att orney No. 34567 IBP No. 12345/2-5-12/Manila PTR No. 87654/12-22-11/Manila Doc. No. ________ Page No. _______ Book No. _______ Series of 2012.