REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF MANILA

6th JUDICIAL REGION
BRANCH 36
ILOILO CITY

PAM OLIVE
Plaintiff.

CIVIL CASE NO. ____

---versus --- For: Ejectment

HIDDEN SHOULDER
Defendant.

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

COMPLAINT

Plaintiff, thru the undersigned counsel, and unto this Honorable Court,
respectfully avers the following:
1. Plaintiff, PAM OLIVE is a resident of No. 1 Safeguard Street,
Green Cross Subdivision, Quezon City; while defendant HIDDEN
SHOULDER is a resident of No. 2 Johnsons, Isoprophyl
Subdivision, Quezon City, where they may be served with
summons.

2. On April 1, 2006, the parties entered into a contract of lease where

Ian Alba is the Lessor and Jun Miranda as Lessee, at a monthly
rental rate FIFTY THOUSAND PESOS (P50,000.00). Copy of
said contract of lease is attached hereto as Annex A and made
an integral part hereof.

3. By virtue of the contract of lease, defendant took occupancy of the

apartment on May 1, 2006.

4. While defendant was up-to-date in the payment of his rentals at the

beginning of the lease, he defaulted in the payments of his rentals
for six (6) months, from January 1, 2007 to June 30, 2007;

5. As a result of defendants refusal to pay his monthly rentals,

plaintiff formally wrote a demand letter on July 25, 2007. Copy of
demand leter is attached hereto as Annex B and made an integral
part hereof.

6. Plaintiff suffered damages by reason of defendants breach of lease

of contract not only of the monthly rental of P50,000.00 for six (6)

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 months until he is eventually ejected therefrom, but also expenses
of litigation and attorneys fees P50,000.00.

7. Plaintiff filed a complaint with the Office of Lupon

Tagapamayapa, but efforts of the latter prove futile, as defendant
adamantly refused to vacate the premises, constraining the Lupon
Tagapamayapa to issue a certificate to file action, copy of which
certificate is attached hereto as Annex C and made an integral
part hereof.

WHEREFORE, in view of the foregoing, plaintiff respectfully prays

to this Honorable Court, that after due hearing, judgment be rendered in
favor of the plaintiff and against the defendants:
1. That they be ordered to pay the plaintiff the sum of THREE
HUNDRED THOUSAND PESOS (Php 300,000.00), which
includes the principal as agreed upon by the parties, and
2. That they be ordered to pay all the legal fees including attorneys
fees and cost of this suit.
Plaintiff further prays for such other relief as the Honorable Court
may deem just and equitable in the premises.

Iloilo City, December 16, 2016.

NONITO Q. PASUELO, JR.

Counsel for Plaintiff
Suite 007, 2nd Floor, Pasuelo Tower
MEGAWORLD, Iloilo City
Roll No. 66199
IBP No. 011 Lifetime
PTR No. 70 - 1/2/16 Iloilo
MCLE Compliance IV No. 001234
Issued on January 12, 2015

VERIFICATION AND CERTIFICATION

I, _PAM OLIVE_, of legal age residing at No. 1 Safeguard Street,

Green Cross Subdivision, Quezon City, after being sworn to in accordance
with law, deposes and says that:
1. I am the Plaintiff in the above-titled case;

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 2. The facts stated in the above complaint are true and correct to the
best of my knowledge and authentic records;

3. I have not commenced any action or filed any claim 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
in them; and

4. If I should learn that the same or similar action or claim has been
filed or is pending after its filing, I shall report that fact within five
(5) days from notice to the court or where the complaint or
initiatory pleading has been filed.
Signed this 26th of August, 2007, in Iloilo City, Philippines.

PAM OLIVE
Affiant

SUBSCRIBED and sworn to before me, this _26th_ day of August,

2007, in the City of Iloilo with SSS No. 07-2157659-3 issued on June 16,
2000 in Iloilo City, Philippines. I hereby certify that I have examined the
affiant.

ROXAN R. LABIS
Notary Public
Roll of Attorney 108831
IBP No. 857218, 01/03/16, Iloilo City
PTR No. 1316719, 01/03/16, Iloilo City
MCLE COMP. NO. IV-0005397, 03/03/16
Doc. No. _______;
Page No. _______;
Book No. _______;
Series of 2007.

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ANNEX A

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 ANNEXB

June 14, 2008

PAM OLIVE
No. 69 North Dakota St., South Carolina Subdivision,
Iloilo City

Sir/Madam:

Greetings!

This is in connection with your leased property in La Paz, Iloilo for a

term of two years starting April 1, 2006, with a monthly rental of Fifty
Thousand Pesos Only (P50,000.00).

My records disclose that you have not made any payment for six (6)
months, from January 1, 2007 to June 30, 2007. The total outstanding
obligation payable to me as of today is Three Hundred Thousand Pesos Only
(P300,000.00).

Accordingly, a FIRST and FINAL DEMAND is hereby made upon

you to settle the amount of Php 300,000.00 within 10 days from receipt of
this letter, Otherwise, I will be constrained to take the necessary legal action
against you.

Thank you.

Yours Truly,

HIDDEN SHOULDER

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ANNEXC

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