REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

City of General Santos
Branch 22

Mr. Uzumaki Naruto, plaintiff Civil Case No. 2

For:Unlawful Detainer

-versus-

Mr. Calvin Klein Romero, defendant

x-----------------------------------------x

COMPLAINT

COMES NOW, the plaintiff together with the undersigned counsel to this most
honorable court, MOST RESPECTFULLY STATES THAT;

1. The Plaintiff is of legal age, married and a resident of Barangay

Mabuhay, General Santos City. The Defendant is likewise of legal age,
married and temporary residing at Barangay Calumpang, General Santos
City.
2. . The Plaintiff is the owner of the two-story house unit located at the
Gensanville Subdivision, General Santos City, and having the residential
address of GV 153 as evidenced by pertinent documents like tax declaration
and deed of sale. (EXHIBIT “A”)
3. The Defendant is the lessee of the house unit that is owned by the
Plaintiff as evidenced by the written contract of lease that both parties signed.
(Exhibit “B”)
4. The Plaintiff and the Defendant came up with a written agreement of
Lease on September 07, 2018, which they both agreed upon and was duly
signed by the two parties as shown in their contract of lease. (Exhibit “B”)
5. Item No. 16 of the contract which the defendant signed expressly provides
that he will only be occupying the property for one (1) year, after which, he will
vacate the house when that term expires. (Exhibit “B”)
6. The contract also provides that the defendant should also take care of the
property and its premises” with the utmost diligence”.
7. On September 15, 2019, the plaintiff, after returning from Canada, was
surprised to discover that the defendant did not vacate the property as he
expected. Worse, he installed a “sari-sari store” in the original building
structure of the house unit.
8. The plaintiff confronted the defendant about it but the defendant claimed
that it was a “DEED OF SALE” which they signed and not a “CONTRACT OF
LEASE” and therefore, the defendant is the new owner of the house unit.
9. On October 20, 2019, after continuous demands, the defendant
constantly refuses to vacate the house unit and even invited relatives to stay
with him.
10. The defendant willfully and maliciously violated the agreement which they
mutually agreed upon, and which the defendant signed.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that judgment be rendered in favor of the plaintiff and that after
judgment;

a. The defendant shall vacate the house unit owned by the plaintiff.

b. The defendant shall be ordered to pay P120, 000 for the Attorney’s Fees.
Such other reliefs and remedies under the premises are likewise prayed
for.

General Santos City, Philippines, this 28th day of October 2019.

Republic of the Philippines )
City of General Santos ) S.S.

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

I, UZUMAKI NARUTO, of legal age, Filipino citizen, single and resident of

Barangay Mabuhay, General Santos City, after having been duly sworn to in accord
Nance 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 29th of October 2019, in the
City of General Santos.

UZUMAKI NARUTO
Complainant

SUBSCRIBED AND SWORN to before me this 29th day of October, 2019, in the City of General
Santos, affiant exhibiting to me his Driver’s License No. 13562 issued by the Land Transportation Office
on February 23, 2015 at the City of General Santos.

Atty. Madelene Grace Q. Crisostomo

Counsel for the Plaintiff
PTR No. 18586456:1-04-07:B.C.
IBP No, 653895:1-04-07:B.C.
Roll No. 42962:5-10-97: Manila
Rm. 4 2/F General Santos City UHUB
180 Pendatun Avenue, General Santos City
Doc. No. ________
Page No. _______
Book No. _______
Series of 2019