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Republic of the Philippines

Municipal Trial Court


Branch 1
Butuan City

Ms. Maine Mendoza, plaintiff Civil Case No. 1


Accompanied by his Attorney in fact, for: Unlawful Detainer
Atty. Andre Juris

-versus-

Mr. Ernesto Mariano, Defendant


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

COMPLAINT
COMES NOW, the plaintiff through undersigned counsel, and to this Honorable Court
respectfully alleges:

1. That plaintiff is of legal age, single, Filipino citizen and residing at Purok 7, Barangay Libertad,
Butuan City where she may be served with court processes, motions, and decision while defendant is of
legal age, a Filipino citizen, single and residing at Pirada, Barangay Plaridel, Cabadbaran City where he
may be served with summons and other court processes;

2. That plaintiff is one of the heirs of the late Spouses Apolonio Mendoza and Virgie Reyes who
are owners of 10,144 square meters of land located at Pirada, Barangay Plaridel, Cabadbaran City as
evidenced by OCT No. Q-1980 and other pertinent documents like Declaration of Real Property;

3. That during the lifetime of her parents, the latter allowed defendant to reside a portion of
that area for residential purposes, provided that his house is made of indigenous materials and he shall
vacate the property when said portion will be used by the owner or their successors;

4. That on August 30, 2016, plaintiff sent a letter of demand to vacate the apartment which was
received by the defendant on September 10, 2016 as shown in the registry return receipt hereto
attached;

5. That despite said letter of demand which was repeated by oral demands, defendant failed
and still refused to vacate the said property;

6. That by reason of the failure of the defendant to vacate the premises, plaintiff was compelled
to file this complaint engaging the services of counsel in the amount of P100,000.00

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that
judgment be rendered in favor of the plaintiff and that after judgment:

a. The defendant shall vacate the property owned by the plaintiff.

b. The defendant shall be ordered to pay P 100,000 for the Attorneys Fees.

Plaintiff prays for such other remedy, as this Honorable Court may deem just and equitable.

Butuan City, Philippines, this 30th day of January 2017.


JURIS LAW OFFICE
Atty. Andre Juris
Counsel for the Plaintiff
PTR No. xxxxxxxx: 1-04-07:B.C.
IBP No. xxxxxx: 1-04-07:B.C.
Roll No. xxxxx: 5-10-97: Butuan
151 J.C. Aquino Avenue,
Barangay Libertad, Butuan City

VERIFICATION AND CERTIFICATION

I, Ms. Maine Mendoza, of legal age, married, Filipino Citizen and a resident of Purok 7, Barangay
Libertad, Butuan City, after being sworn according to law, hereby depose and state that;

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and correct of my
personal knowledge and/or on the basis of copies of documents and records in my possession;

4. I have not commenced any other action or proceeding involving the same issues in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or proceeding is pending in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding has been filed or is pending
before the Supreme Court, the Court of Appeals, or any other tribunal or agency, I undertake to
report that fact within five (5) days therefrom to this Honorable Court.

Maine Mendoza
Complainant

In witness thereof, I, Mr. Andre Juris, counsel of the plaintiff, have herunto set my hand this 30th
of January at Butuan City.

JURIS LAW OFFICE


Atty. Andre Juris
Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Butuan
151 J.C. Aquino Avenue,
Barangay Libertad, Butuan City