REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN THE CITIES

City of ILOILO
Branch 100

YURNERO JUGGERNAUT,
Plaintiff,
CIVIL CASE No. 123456
-versus- FOR: Unlawful Detainer

KAEL INVOKER,
Defendant.

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COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most
respectfully avers:

1. That the plaintiff, YURNERO JUGGERNAUT, is of legal age, Filipino citizen, single, with
residence and postal address at 1000 Javellana St., Jaro, Iloilo City.
2. That the defendant, KAEL INVOKER, is of legal age, Filipino citizen, single, with residence and
postal address at 2000 San Jose St., Jaro, Iloilo City where they may be served with summons and
other court processes;
3. The plaintiff is the owner of a land over which an apartment had been constructed located 3000
Jalandoni Street, Iloilo City.
4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid apartment for
a consideration of P15,000.00 a month as rental to be paid within the first five (5) days of each
month starting November 3, 2017;
5. The defendant failed to pay the agreed rental for several months starting October, 2018 up to the
present;
6. On December 3, 2018, the plaintiff sent a letter of demand to vacate the apartment which was
received by the defendant as shown in the registry return receipt hereto attached as Annex “A”;
7. Despite said letter of demand which was repeated by oral demands, the defendant failed and still
refused to pay the agreed amount of rentals and to vacated the apartment;
8. By reason of failure of the defendant to vacate the premises and to pay the unpaid rentals, the
plaintiff was compelled to file this complaint engaging the services of counsel in the amount of
P30,000.00.

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that,
after hearing, judgment be rendered ordering the defendant:

1. To vacate the subject premises;

2. To pay the amount of P15,000.00 per month as compensation for the reasonable use of the subject
premises until they finally vacate the said premises;
3. To pay the plaintiff the cost of the suit.

City of Iloilo, January 18, 2019.

 Atty. Renzo Beaver B. Balberona
Counsel for Plaintiff
PTR No. 1111111, Iloilo City, 1/2/19
IBP OR No. 222222, IloiloCity, 1/2/19
Attorney’s Roll No. 33333
MCLE Compliance Certificate No. IV-0044444,Iloilo
City, 1/2/19
 VERIFICATION/CERTIFICATION OF NON-FORUMSHOPPING

I, YURNERO JUGGERNAUT, of legal age, Filipino, after having been sworn, in accordance with law,
hereby depose and state that:

1. I am the Plaintiff in the above-captioned case;

2. I have read and understood the contents hereof of this Petition for Review, and the facts herein
alleged are true and correct of my own knowledge and based on available verifiable records;

3. I heretofore have not commenced any other action or proceeding or any claim, or filed any claim
involving the same issues raised in the above-captioned case, in this Honorable Supreme Court, in
the Court of Appeals, nor the different Divisions thereof, nor in any other court or tribunal or agency
and, to the best of my knowledge, no such other action or claim is pending therein;

4. I hereby undertake to notify this Honorable Court of such fact within five (5) days from receipt of
such knowledge, should I come to learn that the same or a similar action or claim has been filed or
pending in the Supreme Court, Court of Appeals, the different Divisions thereof, or any other court
or tribunal or agency;

5. I am executing this sworn statement in compliance with Section 5, Rule 7 of the 1997 Rules of
Court.

YURNERO JUGGERNAUT

Affiant

SUBSCRIBED and SWORN TO before me this 31stday ofAugust 2018 at Iloilo City,
Philippines, affiant exhibiting tome her SSS ID with ID No. 1234567890 issued by the Social Security
System, as competent evidence of her identity, and she personally acknowledged to me that the foregoing
“Petition” is her free and voluntary act and deed. Machine copy of this SSS ID is hereto attached.

Atty. Nereo Avocado

Notary Public
PTR No. 1234567, Iloilo City, 1/2/19
IBP OR No. 654321, Iloilo City, 1/2/19
Attorney’s Roll No. 99999
MCLE Compliance Certificate No. IV-0022222,Iloilo
City, 1/2/19

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