Republic of the Philippines

Municipal Trial Court

Branch 5
Baguio City

Mr. Uzumaki Naruto, plaintiff Civil Case No. 2

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

-versus-

Mr. Uchiha Sasuke, Defendant

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

COMPLAINT

COMES NOW, the plaintiff together with the undersigned counsel to this most
honorable court, MOST RESPECTFULLY STATES THAT;

1. The Plaintiff is of legal age, married and a resident of Puguis, La Trinidad Benguet. The Defendant
is likewise of legal age, married and temporary residing at Petersville Subdivision, Baguio City.
2. The Plaintiff is the owner of the two-storey house unit located at the Petersville Subdivision,
Baguio City, and having the residential address of PV 123 as evidenced by pertinent documents
like tax declaration and deed of sale. ( EXHIBIT A )
3. The Defendant is the lessee of the house unit that is owned by the Plaintiff as evidenced by the
written contract of lease that both parties signed. (Exhibit B)
4. The Plaintiff and the Defendant came up with a written agreement of Lease on June 26, 2007,
which they both agreed upon and was duly signed by the two parties as shown in their contract of
lease. (Exhibit B)
5. Item No. 16 of the contract which the defendant signed expressly provides that he will only be
occupying the property for one (1) year, after which, he will vacate the house when that term
expires. (Exhibit B)
6. The contract also provides that the defendant should also take care of the property and its
premises with the utmost diligence.
7. On June 28, 2008, the plaintiff, after returning from Japan, was surprised to discover that the
defendant did not vacate the property as he expected. Worse, he installed a sari-sari store in the
original building structure of the house unit.
8. The plaintiff confronted the defendant about it but the defendant claimed that it was a DEED OF
SALE which they signed and not a CONTRACT OF LEASE and therefore, the defendant is
the new owner of the house unit.
9. On August 20, 2008, after continuous demands, the defendant constantly refuses to vacate the
house unit and even invited relatives to stay with him.
10. The defendant willfully and maliciously violated the agreement which they mutually agreed upon,
and which the defendant signed.

PRAYER

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

a. The defendant shall vacate the house unit owned by the plaintiff.
b. The defendant shall be ordered to pay P 120, 000 for the Attorneys Fees.

Such other reliefs and remedies under the premises are likewise prayed for.

Baguio City, Philippines, this 28th day of September 2008.

Poging Attorney
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: Manila
Rm. 4 2/F Baguio Boating Center
180 Burnham Lake, Baguio City

VERIFICATION AND CERTIFICATION

I, Mr. Uzumaki Naruto, of Legal age, married, Filipino Citizen and a resident of Puguis, La
Trinidad Benguet, 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.

Uzumaki Naruto
Complainant

In witness thereof, I, Mr. Poging Attorney, counsel of the plaintiff, have herunto set my hand this
29th of September at Baguio City.

Poging Attorney
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: Manila
Rm. 4 2/F Baguio Boating Center
180 Burnham Lake, Baguio City