REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

City of Digos
Branch 1

REKY LAMO,
Plaintiff,
CIVIL CASE No.
98765
-versus-

FOR: Unlawful Detainer

DELLY MUHAWA,
Defendant.
x-----------------------------------x
COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1. That the plaintiff, REKY LAMO, is of legal age, Filipino citizen, single, with
residence and postal address at 123 Estrada Street, Digos City, Davao del Sur;
2. That the defendant, DELLY MUHAWA, is of legal age, Filipino citizen, single, with
residence and postal address at 456 Estrada Street, Digos City, Davao del Sur
where they may be served with summons and other court processes;
3. The plaintiff is the owner of a land over which an apartment had been
constructed located 456 Estrada Street, Digos City, Davao del Sur;

4. By virtue of a contract of lease, the plaintiff leased unto the defendant the
aforesaid apartment for a consideration of P5,000.00 a month as rental to be
paid within the first ten (10) days of each month starting December 1, 2014;
5. The defendant failed to pay the agreed rental for several months starting
February 14, 2015 up to the present;
6. On May 1, 2015, the plaintiff sent a letter of demand to vacate the apartment
which was received by the defendant as shown in the registry return receipt
hereto attached as Annex A;
7. 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
vacated the apartment;
8. The dispute was referred to the Lupong Tagapamayapa to attempt settlement in
accordance with the Katarungang Pambarangay Law but the defendant did not
heed to settle the dispute. The certificate issued by the Lupong Tagapamayapa is
attached herein as Annex B;

9. By reason of failure of the defendant to vacate the premises and to pay the
unpaid rentals after earnest efforts for an amicable settlement of the matter
between the parties had been exerted, but that none was reached. 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 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 P5,000.00 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 Digos, July 2, 2015.
OMEGA, JALA AND HERRERO LAW OFFICE
Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Manila
By:

Alfie Luzana Omega

Roll of Attorney No. 70567
IBP No. 12345/2-5-12/Digos
PTR No. 87654/12-22-11/Digos

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )
City of Digos
) S.S.

I, REKY LAMO of legal age, Filipino citizen, single and resident of 123 Estrada
Street, Digos City, Davao del Sur, after having been duly sworn to in accordance with
law do hereby depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That 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 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;
6. I executed this verification/certification to attest to the truth of the foregoing facts
and to comply with the provisions of Adm. Circular No. 04-94 of the Honorable
Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 2nd day of July
2015, in the City of Digos.

REKY LAMO
SUBSCRIBED AND SWORN to before me this 2nd day of July 2015, in the City
of Digos, affiant exhibiting to me his Drivers License No. 12345 issued by the Land
Transportation Office on April 8, 2015 at the City of Digos.

ATTY. ALFIE LUZANA OMEGA

Notary Public
My Commission Expires Dec. 31, 2015
Roll of Attorney No. 70567
IBP No. 12345/2-5-12/Digos
PTR No. 87654/12-22-11/Digos
Doc. No. 222
Page No. 20
Book No. 1
Series of 2015.