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 Attorney’s 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