REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Manila

Branch 1

KRUL ACOSTA,

Plaintiff,

CIVIL CASE No. 98765

-versus- FOR: Unlawful Detainer

MEGAN VITUG,

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, KRUL ACOSTA, is of legal age, Filipino citizen,

single, with residence and postal address at 123 Benitez Street,
Manila;
2. That the defendant, MEGAN VITUG, is of legal age, Filipino citizen,
single, with residence and postal address at 456 Modesto Street,
Manila, where they may be served with summons and other court
processes;
3. The plaintiff is the owner of a land over which and apartment had
been constructed located 654 San Pedro Street, Manila;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant
the aforesaid apartment for a consideration of P5,000.00 a month as
rental to be paid within the first ten (10) days of each month starting
November 3, 2011;
5. The defendant failed to pay agreed rental for several months starting
February 19, 2012 up to the present;
6. On May 3, 2012, 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 complain
engaging the services of counsel in the amount of P10,000.00.

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 P5,000.00 per month as compensation for
reasonable use of the subject premises until they final vacate the
said premises;
3. To pay the plaintiff the cost of the suit

City of Manila, September 24, 2012.

REYES, TOLENTINO AND CRUZ LAW OFFICE

Counsel for the Plaintiff

Unit 123, Victoria Tower I

Taft Avenue, Manila

By:

Louise Reyes

Roll of Attorney No. 98765

IBP No. 1234/2-5-12/Manila

PTR No. 87654/12-22-11/Manila