Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION Branch 6 Baguio City

FLORDELIZA TORRES, Petitioners. -vsDANIEL UYTINGCO,

COMPLAINT FOR EJECTMENT Case No.: _____

COMPLAINT
COMES NOW the Plaintiff in the above entitled case, through counsel, and to this Honorable Court alleges; I That the plaintiff is of legal age and a resident of the City of Baguio; that defendant is likewise of legal age, residing at No. 2 Cruz Street, Baguio and may be served with summons at said address; II That defendant on September 7, 2011, leased from the plaintiff the premises located at No. 7 Cruz Street, Baguio City, agreeing to pay monthly rental of P 10, 000.00 III However, defendant failed to pay the aforesaid monthly rentals on their due dates, such that as of the date hereof, his arrearages have accumulated up to P50,000.00; IV That on February 7, 2012, demands was made on defendant to pay his rental in arrears and vacate the premises, but despite said demands, written and oral, defendant failed and refused to pay the rentals in arrears and vacate the premises leased by him; V As a result, plaintiff was constrained to institute this case, incurring in the process obligations for litigation expenses and attorneys fees in the amount of Php 20,000.00. PRAYER WHEREFORE, it is respectfully prayed that judgment be rendered against the defendant ordering him: 1. To vacate the premises leased by him;

2.

To pay the monthly sum of P10, 000.00 beginning with the month of September 7, 2011, with interest thereon at the legal rate until fully paid until the defendant vacates said premises; To pay the sum of P30,000.00 as litigation expenses and attorneys fees.

3.

Plaintiff further prays for such other reliefs as this Court may deem just and equitable. Baguio City, Philippines, March 12,2012.

RHODORA ZAMBRANO COUNSEL FOR THE PLAINTIFF PTR No. 8001/ 01-01-09/ Baguio City Roll No. 39876 IBP Lifetime Member No. 40063/Baguio City MCLE Compliance No. 12345 Suite 2013, Victory Building Session Road, Baguio City

REPUBLIC OF THE PHILIPPINES } CITY OF BAGUIO } S.S. x--------------------------------------------x VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING I, FLORDELIZA TORRES, of legal age, Filipino citizen and a resident of Km. 4 Marcos Highway, Baguio City, after being duly sworn in accordance with law, hereby depose and state: 1. That I am the Plaintiff in the above-entitled case; 2. That I have caused the preparation of the COMPLAINT FOR EJECTMENT; 3. That I have read the material and relevant allegations therein contained are true and correct of my personal knowledge and authentic documents; 4. That I hereby certify that I have not heretofore commenced any action or filed any claim involving the same issues before any other court, tribunal or quasi-judicial agency; 5. That to the best of my knowledge, there is no such pending action or claim, and that if I should hereafter learn that the same or similar action or claim has been filed or is pending, I shall report such fact within five (5) days therefrom to the Honorable Court. IN WITNESS WHEREOF, I have hereunto affixed my signature this 12 th day of MARCH 2012, in the City of Baguio, Philippines. FLORDELIZA TORRES Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio this 12th day of March 2012 by FLORDELIZA TORRES, who is personally known to me, and who is the same person who personally signed before me the foregoing affidavit and acknowledged that he executed the same.

MARY JOY OLUT NOTARY PUBLIC Until December 31, 2012 PTR No. 02379/ 01-01-09/ Baguio City Roll No. 37931 IBP Lifetime Member No. 56789/Baguio City MCLE Compliance No. 23456 Rm 5007, Tower Mansion Session Road, Baguio City

Doc. No._______ Page No._______ Book No._______ Series of 2012