Republic of the Philippines
MUNICIPAL
TRIAL COURT (IN CITIES)
(Name of
City / Municipality)
(NAME OF PLAINTIFF)
Plaintiff,
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Civil Case No. ______
For: Unlawful Detainer
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-versus-
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(NAME OF DEFENDANT),
Defendant.
x-
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COMPLAINT
PLAINTIFF, by counsel, and unto this
Honorable Court, most respectfully allege: -THAT-
1.
Plaintiff is of legal age, Filipino, with
residence and postal address at (Residential
address of plaintiff) where he may be served notices and other court
processes;
2.
Defendant is of legal age, Filipino, with
residence and postal address at (Residential
address of defendant), where he may be served summons and other court
processes;
3.
Plaintiff is the absolute owner and lessor of
that certain townhouse situated at (Location
of property) and now leased and occupied by the Defendant;
4.
The Defendant leases and occupies the said townhouse
from March 1, 2012 until February 28, 2017 as agreed upon between the plaintiff
and the Defendant in the lease contract executed on March 1, 2012 under the
express obligation to pay a monthly rental of P20,000.00; (Contract of Lease attached as Annex
“A”)
5.
The lease contract of the Defendant for the
occupation of the building has been terminated on February 28, 2017 and has not
been renewed or extended;
6.
During the course of the Defendant’s occupation
of the said townhouse, Defendant has failed to pay his rentals for the months
of June 2016 to February 2017;
7.
Defendant has continued to occupy the said townhouse
notwithstanding the fact that her contract of lease has been terminated on February
28, 2017 thus depriving the plaintiff from having the said townhouse leased by
other persons;
8.
Several demands to vacate was made by plaintiff
to Defendant, both oral and written (Demand
letter attached as Annex “B”),
but Defendant refused to vacate the said townhouse and return possession to the
plaintiff;
9.
Until now Defendant still refuses to vacate and
restore possession and pay her rentals for the months June 2016 to February
2017 during her occupation of the townhouse;
10.
Thus, Defendant is unlawfully withholding
possession of the subject townhouse from the plaintiff despite last and final
demand, to the damage and prejudice of the plaintiff;
11.
Before filing of this complaint, the dispute
has been referred to the Lupong Tagamayapa of (Name of City or Municipality) but the parties failed to arrive at
an amicable settlement; (Certificate to
File Action 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 townhouse;
2.
For the payment of ONE HUNDRED THOUSAND (PhP180,000.00)
PESOS, 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.
(Place of
Filing),
Philippines, (Date of Filing).
(NAME OF LAW OFFICE)
Counsel for Plaintiff
(Address of law office)
By:
(NAME OF LAWYER)
Roll
No.: ____________
PTR
No: ____________
IBP
No.: ____________
MCLE
Compliance No.: ____________
ATTACH:
Verification and Certification
of Non-forum Shopping
Annexes
