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Complaint: Advanced Foundation Construction Systems Corporation
Complaint: Advanced Foundation Construction Systems Corporation
GIANNI MODICA,
and all persons claiming rights under him,
Defendants.
x--------------------------------------------------------x
COMPLAINT
358 Senator Gil Puyat Avenue, Makati City herein represented by Ms.
with address at Unit 604 Somerset Tower I, Leveriza Street, Pasay City,
where he may be served with summons and other court processes
(hereinafter DEFENDANT for brevity);
rentals. A photocopy of said letter dated July 17, 2012 is hereto attached and
marked as Annex F.
Photocopies of Demand Letter dated July 17, 2013 and the Affidavit of
Service of plaintiffs messenger, who served the Demand Letter unto the
defendant, are hereto made as integral parts hereof and marked as Annexes
G and H.
13. The one year period for the filing of an ejectment case is
reckoned from the date of the last demand;
14. Despite the fact that the defendant is not anymore entitled to the
occupation and possession of the subject Unit by virtue of the expiration of
contract, the non-payment of rentals, and final notice and demand to vacate
the same, defendant refused and continuously fails to restore plaintiff AFCSC
to the possession of the subject Unit;
16. As the defendant is adamant in his refusal to vacate the Unit and
to enforce its rights and interest, AFCSC was constrained to institute this suit
and engage the services of a counsel for which AFCSC has to incur attorneys
fees of TWENTY THOUSAND PESOS (Php 20,000.00);
17. To serve as an example for the public good to the end that a
person be discouraged from the unlawful possession of a property to which
he has no more right whatsoever, AFCSC should be awarded exemplary
damages of TWENTY THOUSAND PESOS (Php20,000.00);
3. Costs of suit.
Other reliefs just and equitable under the premises are also prayed for.
I, SUZETTE R. ESMA, of legal age and Filipino, after having been duly sworn to
in accordance with law, depose and state THAT:
SUZETTE R. ESMA
Affiant
SUBSCRIBED AND SWORN to before me this July ___, 2013; affiant exhibited to
me her SSS I.D. Number __________________ .