Republic of the Philippines

_________Judicial Region
Municipal Trial Court
Branch ___________

__________________,
Plaintiff,

-versus- Civil Case No. __________

For: Unlawful Detainer

_____________________,
Defendant.
x----------------------------------------------x

COMPLAINT
PLAINTIFF, through counsel, and before this Honorable Court,
respectfully alleges that:

I. The Parties:

1.1. Plaintiff is a Filipino Citizen, of legal age, and residing

at _________________________, where she/he may be served
with notices and other court’s processes.

1.2. Defendant __________________ is a Filipino Citizen,

of legal age, and residing at _____________________________,
where he/she may be served with summons, notices and other
court’s processes.

II. Causes of Action:

2.1. The plaintiff is the owner of a land over which an

apartment had been constructed located at
_____________________________;

2.2. By virtue of a contract of lease, the plaintiff leased

unto the defendant the aforesaid apartment for a consideration of
P__________________ a month as rental to be paid within
___________ (___) days of each month starting
_________________;

2.3. The defendant failed to pay the agreed rental for

several months starting _______________ up to the present;

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 2.4. On __________, 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”;

2.5. 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 vacate the apartment. Resort to
Barangay Conciliation proceedings proved useless for failure of
the defendant to appear before the Lupong Tagapamayapa. A
Certification to File Action is attached as Annex “B”;

2.11. Plaintiff has no other recourse but to file this complaint.

2.12. Plaintiff was constrained to engage the services of

counsel to assert her right of possession over the apartment unit,
in the amount of __________ Pesos (P0.00) and P0.00 per court
appearance, copy of the Official Receipt is hereto attached as
Annex “C”

2.13. For the deprivation of the Plaintiff’s right of possession,

and therefore, she cannot lease it to another lessee, she suffered
and continues to suffer loss of income, thus, Defendant must pay
the Plaintiff P0.00 per month from ____________ up to the time
she voluntarily vacates the premises as actual damages.

2.14. In order to deter the defendant to do what she did to

Plaintiff to other persons in similar situation, Defendant must
likewise be directed to pay the Plaintiff exemplary damages in the
amount of P0.00.

2.16. For the deprivation of the plaintiff’s right to exercise

dominion over the property which she owns, she suffered and
continue to suffer sleepless nights and injured reputation, for which
she must be reimbursed by the defendant, in the amount of P0.00
for and by way of moral damages.

WHEREFORE, it is most respectfully prayed by the Plaintiff,

before this Honorable Court, that after due notice and hearing,
judgment be rendered in favor of the Plaintiff, as follows:

a. Directing the Defendant to vacate the apartment

unit.

b. Ordering the Defendant to pay the Plaintiff the

following:

1. P0.00 for and by way of attorney’s fees

plus P0.00 per court’s appearance;

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 2. P0.00, for and by way of moral
damages;

3. P0.00, for and by way of exemplary

damages; and

4. cost of litigation.

c. Directing Defendant to pay the Plaintiff P0.00 per month

as rental fee starting from the time she failed to pay her monthly
rental fee up to the time she voluntarily vacate the premises or
upon order of the court.

Other reliefs just and equitable are likewise prayed for.

City of Legazpi, Philippines, 14 September 2020.

__________ LAW OFFICE

(Address)
Tel. No. ________________
Email add: _________________

ATTY. _________________
Counsel for the Plaintiff
PTR No. _________________
IBP No. _________________
Roll of Attorneys No. ______
MCLE Compliance No. ______
Date Issued: ______________

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Republic of the Philippines)
City of _______ )s.s

VERIFICATION AND CERTIFICATION AGAINST FORUM-

SHOPPING

I, ________________, of legal age, Filipino and a resident of

_________________________, after being sworn to in accordance with
law, hereby depose and state that:

1. I am the Complainant Corporation in the above-entitled case

and I have caused the preparation of the foregoing Complaint;
2. I have read and understood the contents thereof and the
allegations therein are true and correct of my own personal knowledge
and/or based on authentic records;

3. The complaint is not filed to harass, cause unnecessary

delay or needlessly increase the cost of litigation;

4. The factual allegations therein have evidentiary support or, if

specifically so identified will likewise have evidentiary support after a
reasonable opportunity for discovery;

5. I have not commenced any action involving the same issues

in the Supreme Court, the Court of Appeals, or different divisions thereof
or any other tribunal or agency;

6. To the best of my knowledge, no such action or proceeding

is pending in the Supreme Court, the Court of Appeals or any other
tribunal or agency; and

7. If I should learn that an action or proceeding similar to the

present petition has been or is pending before the Honorable Court, the
Court of Appeals, or any other tribunal or agency, I hereby undertake to
report the same within five (5) days to this Honorable Court.

IN WITNESS WHEREOF, I hereunto affixed my signature this

____ day of ______ 2020 at ____________.

_________________
Affiant
ID No. ___________

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 SUBSCRIBED AND SWORN to before me this __day of _____
2020 at __________, Philippines, affiant exhibiting to me her
Identification Number as indicated above.

NOTARY PUBLIC

Doc. No.:__________;
Page No.:__________;
Book No.:__________;
Series of 2020.