Republic of the Philippines

REGIONAL TRIAL COURT OF NEGROS ORIENTAL

7th Judicial Region
Branch 6
Dumaguete City

Grey Boi, Civil Case No. 123456

Plaintiff, For: Breach of Contract
-versus-
Zia Girl,
Defendant.
X-------------------------------------X
COMPLAINT

COMES NOW, the Plaintiff by the undersigned counsel unto the Honorable Court
respectfully alleges:
1. That Plaintiff is of legal age, single, Filipino citizen, and a resident of Dumaguete
City where he may be served with summons and other court processes;

2. That Defendant is of legal age, married, Filipino citizen, and a resident of

Dumaguete City where he may be served with summons and other court
processes;

3. That the Plaintiff herein is the lessee of the commercial building located at Colon
Street Dumaguete City;

4. That the Defendant herein is the lessor and the owner of the commercial building
located at Colon Street Dumaguete City;

5. That on January 21, 2018, the Plaintiff and the Defendant executed the Contract
of Lease;

Attached herewith is the Contract of Lease marked as “Annex A”;

6. That the term of lease is for one (1) year from February 14, 2018 to February 13,
2019;

7. That the Defendant want the Plaintiff to vacate the said commercial building on
November 16, 2018 without any justifiable cause under the terms and conditions
in the Lease of Contract;

8. That the Defendant with other men compel the employee of the Plaintiff to vacate
the said premises on December 1, 2018;
9. That Plaintiff requested the Defendant to have an amicable settlement over the
contract of lease on December 15, 2018, however, the Defendant failed and refused
to appear in the settlement.
 PRAYER

IN THE LIGHT OF FOREGOING, it is most respectfully prayed of this

Honorable Court that after due notice and hearing, judgment be rendered in favor
of Plaintiff and against Defendant ordering the latter, as follows:

1. To compel the Defendant to forego with the Lease Contract;

2. To pay and liquidated damages in the estimated amount of Ten Thousand

Pesos (Php 10,000.00) for the unrealized profits and expenses incurred by
Plaintiff in pursuing the lease contract;

3. To pay Attorney’s fees Ten Thousand Pesos (Php 10,000.00) plus One
Thousand Five Hundred Pesos (Php 1,500.00) per court appearance;

4. To pay cost of the suit.

Other relief and remedies that are just and equitable under the premises are
likewise prayed for.

Dumaguete City, January 21, 2019.

Cactus Law Firm

Counsel for the Plaintiff
By: Atty. Mark Anthony R Delmo
Atty. Mark J Susania
Colon St., Dumaguete City
PTR No. 12345, 01/05/16
IBP Life Member Roll No. 12345
Roll of Attorney’s No. 12345
MCLE Compliance No. 12345, 01/30/16

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, Grey Boi, of legal age, single, Filipino and the Plaintiff in the above entitled
case, after being duly sworn to in accordance with the law do hereby depose and say;

1. That I am the Plaintiff in the above-entitled case;

2. That I cause the preparation of the complaint and I read the allegations contained
therein and understood each of them to be true and correct of my own personal
knowledge and beliefs and base on authentic documents;

3. That I further certify that I have not commenced any action or proceeding
involving the same issues in the Supreme Court, Court of Appeals or different
divisions thereof, or any court, tribunal or agency;

4. That should I learn hereafter of the filing or pendency of such actions, I undertake
to inform this Honorable Court of said fact within five (5) days from knowledge
therefrom.
 IN WITNESS WHEREOF,I have hereunto affixed my signature this 21 st day of
January 2019 at Dumaguete City.

(SGD) Grey Boi

Plaintiff

SUBSCRIBED AND SWORN TO BEFORE ME, this 21st day of January 2019 at
Dumaguete City, affiant exhibiting to me his Driver’s License No. 12345, issued on May
28, 2017 and valid until May 27, 2023.

(SGD) ATTY. Sha Sha

Notary Public
PTR No. 12345, 01/05/16, Dumaguete City
IBP Life Member Roll No. 12345
Roll of Attorney’s No. 1234
MCLE Compliance No. 12345, 01/30/16

Doc. No. 85;

Page No. 40;
Book No. 20;
Series of 2019