Complaint for Unlawful Detainer Sample

REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT
City of Manila
Branch 1

KRUL ACOSTA,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Unlawful Detainer

MEGAN VITUG,
Defendant.

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COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
1. That the plaintiff, KRUL ACOSTA, is of legal age, Filipino citizen, single,
with residence and postal address at 123 Benitez Street, Manila;
2. That the defendant, MEGAN VITUG, is of legal age, Filipino citizen, single,
with residence and postal address at 456 Modesto Street, Manila, 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 654 San Pedro Street, Manila;
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 November 3, 2011;
5. The defendant failed to pay the agreed rental for several months starting
February 19, 2012 up to the present;
6. On May 3, 2012, 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. By reason of failure of the defendant to vacate the premises and to pay the
unpaid rentals, 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 Manila, September 24, 2012.

REYES, TOLENTINO AND CRUZ LAW OFFICE

Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Manila

By:
Louise Reyes
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Manila ) S.S.
 I, KRUL ACOSTA, of legal age, Filipino citizen, single and resident of 123
Benitez Street, Manila, 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 24th of
September 2012, in the City of Manila.

KRUL ACOSTA

SUBSCRIBED AND SWORN to before me this _______ day of September,

2012, in the City of Manila, affiant exhibiting to me his Drivers License No. 12345
issued by the Land Transportation Office on April 8, 2012 at the City of Manila.

ATTY. NO CASE
Notary Public
My Commission Expires Dec. 31, 2012
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila
Doc. No. ________
Page No. _______
Book No. _______
Series of 2012.