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Republic of the Philippines

______________ Judicial Region


MUNICIPAL TRIAL COURT
_________________
_________________________
_______,
INC.
(_______________),
Plaintiff,
versus
Civil
Case
No.
____________
For: Forcible Entry
_________________________
,
_________________________
,
_________________________
, and/or any person/s
holding interest or claim
thru them,
Defendant/s.
x----------------------------------x

COMPLAINT
COMES NOW, the plaintiff, by the undersigned
counsel, and unto this Honorable Court, respectfully files this
complaint and alleges that:
1.

The plaintiff is a domestic corporation duly organized and


existing under Philippine laws, with principal office address
at
__________________________________,
and
is
herein
represented
by
its
_________________________,
__________________________, Filipino, of legal age, married and
with office address at ____________________________, by virtue
of a Board Resolution dated ________________________ 2012. A
copy of the Secretarys Certificate signifying such resolution
is hereto attached as Annex A and is made an integral part
hereof;

2.

The defendants are all of legal age, Filipinos, and currently


residing at Block __ Lot __, ___________________ Subdivision,
Brgy. _______________, ________________, _______________, where
they may be served with summons and other court
processes;

3.

At all times material to this complaint, the plaintiff is the


owner/developer of the entire _________________________,
Subdivision,
located
in
Brgy.
_________________,
_________________, _________________, including the abovementioned house and lot currently being occupied by herein
defendants at the above-stated address, covered by Tax
Declaration No. _________________ and Transfer Certificate of
Title (TCT) No. _________________ of the Registry of Deeds for
the Province of _________________ (see Annexes B and
C hereof);

4.

Sometime in _________________ or thereabout, plaintiff


discovered that the defendants had broken the padlock and
had entered into the said unit without consent from herein
plaintiff;

5.

Due to the unlawful occupation of defendants on the above


described unit, plaintiff sent a notice to vacate (see Annex
C hereof) last _________________, ordering defendants to
vacate the subject property which the defendants simply
ignored. To date, defendants, despite the foregoing notice to
vacate, refused and continue to refuse to vacate or leave the
unit;

6.

Defendants continued stay or occupancy of plaintiffs unit


on Block __ Lot __, _________________ Subdivision is illegal and
unauthorized since plaintiff remains the registered owner of
said housing unit. Thus, plaintiff is therefore entitled to
demand from the defendant rental payments or reasonable
compensation for his occupancy or possession of said unit;

7.

Due to the refusal of the defendant to vacate the unit, the


plaintiff has suffered opportunity lost equivalent to
________________ Thousand _________________ Hundred
________________ and __/100 Pesos (Php _________________)
per month, effective _________________ and every year

thereafter, until the defendant shall have vacated the


premises;
8.

As a result of the stubborn defendants refusal to peacefully


leave and/or vacate the unit, plaintiff was constrained to
engage the services of counsel for a fee and for which
defendant should be held answerable in the amount of
Twenty Thousand Pesos (Php 20,000.00) as and by way
of attorneys fees plus cost of suit.

PRAYER
WHEREFORE, premises considered, it is respectfully
prayed that after due notice and hearing, judgment be
rendered in favor of the plaintiff as follows:
(a)

ORDERING the defendants and/or any one claiming right,


interest or claim therefrom, to immediately and peacefully
vacate the unit at Block __ Lot __, _________________
Subdivision,
Brgy.
_________________,
_________________,
_________________, without any damage on the same, thus
immediately allowing the plaintiff to recover possession of
said property;

(b)

ORDERING the defendants and/or anyone claiming right,


interest or claim therefrom, to pay compensatory damages
representing
monthly
rentals
in
the
amount
of
________________ Thousand _________________ Hundred
________________ and __/100 Pesos (Php _________________)
per month from the filing of this complaint until they
actually vacate the said property; and

(c)

ORDERING the defendants to reimburse the plaintiff for


attorneys fees of Twenty Thousand Pesos (Php
20,000.00), the cost of suit and the expenses of litigation.
Other reliefs just and equitable are likewise prayed for.
RESPECTFULLY SUBMITTED.
______________________ City for ________________,
_________________. This ________________________.

______________________________
______________________________
Counsel for Plaintiff
_______________________ City
IBP
No.
_________________
__/__/__, Manila Chapter
PTR
No.
______________,
__/__/__, Manila Chapter
Roll No. ____________
MCLE Compliance No. IV_________________, __/__/__
VERIFICATION AND CERTIFICATION
I, ____________________________, of legal age, Filipino,
married
and
with
office
address
at
_________________________________, after being sworn to in
accordance with law, hereby depose and say that:
1. I am the _____________________________________ of the plaintiffcorporation in the above-mentioned case;
2. I am duly authorized1 to represent the said respondent in the
above-entitled case, file Complaint and other pleadings
required by law, and to sign the certification and/or
verification thereof;
3. I caused the preparation of this Complaint;
4. I have read the contents thereof and they are true and
correct of my own personal knowledge and/or based on
authentic records in my possession;
5. I hereby certify that I have not commenced any other action
involving the same issues the same issues before the
Supreme Court, Court of Appeals or any of its Divisions, or
any other tribunal agency;

1 See Annex A

6. If there is such other action or proceeding, I shall inform this


Honorable Office the status thereof, and that if I should
thereafter learn that a similar action or proceeding has been
filed or is pending before the Supreme Court, Court of
Appeals or any of its Divisions, or any other tribunal agency,
I shall promptly inform the aforesaid Courts and other
tribunal or agency thereof of such fact within five (5) days
therefrom.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this ______________ in _________________________ City.

______________________________
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME, on the
date and place above-written, personally appeared, affiant
___________________________, who exhibited to me his/her
government-issued identification denominated SSS ID No.
__________________ bearing his/her photograph and genuine
signature as competent evidence of identity in accordance
with the Rules on Notarial Practice.

Doc. No.___;
Page No. ___;
Book No. ___;
Series of 2016.