REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL REGION

METROPOLITAN TRIAL COURT

BRANCH ________ CALOOCAN CITY

VERONA C. SADIASA AND MERLINA C. SADIASA

Plaintiffs, CIVIL CASE NO.____________
-versus- For: UNLAWFUL DETAINER
SPS. JOHN DE GUZMAN , CLEOFE DE GUZMAN
AND ALL PERSONS CLAIMING RIGHTS UNDER THEM,
Defendants.
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COMPLAINT

We, VERONA C. SADIASA and MERLINA C. SADIASA, (“PLAINTIFFS”) unto this

Honorable Court respectfully state that:

THE PARTIES
1. We, the “Plaintiffs” are of legal ages, Filipino Citizens, with residence and postal address
at 114 J.P. Rizal St. Brgy. 35 Maypajo Caloocan City where they can be served with
notices and other processes of this Honorable Court.

2. “Defendants” Sps. John De Guzman and Cleofe De Guzman and all persons claiming
rights under them, are all Filipinos, of legal ages, and current residents of the property
subject of this case or at 1137 Road 3 Tambakan St. Maypajo Caloocan City, where
they may be served with summons and other pertinent processes of this Honorable
Court.

CAUSE/S OF ACTION
3. Prior to it’s lease to the Defendants and at all times material to the present action,
PLAINTIFFS and/or their predecessors-in-interest are the lawful possessors in concept
of owner of the subject property, or a parcel of land located at 1137 Road 3 Tambakan
St. Maypajo Caloocan City, Metro Manila where we built an apartment building with 4
units of strong materials and related improvements.
Copies of pictures of the Subject Property are attached hereto and made integral parts
hereof Annex “A”.
4. We are also members of . COROHAFFA INC., an association of homeowners in the
barangay where the subject property is located. COROHAFFA INC. is duly accredited
by Securities and Exchange Commission with SEC Reg. No. CN201613774.

On July 29, 2018, with the help of Mr. Marcos P. Grio; Founding Chairman of
COROHAFFA INC. He issued a Demand Letter to the Defendants, to vacate our
residential unit.
 A copy of aforementioned Demand Letter is attached hereto and made integral parts
hereof Annex “B”
5. We are also the addressee of billing statements and official receipts issued by
MERALCO and MAYNILAD for electricity and water consumed by the subject property.

Copies of Official Receipt issued by Meralco and Maynilad to us the Plaintiffs under
Maynilad Account No. 0011853501-8 and Meralco Account No.06106202010 are
attached hereto and made integral parts hereof Annexes “C and D”.

6. On September 3, 2001, Defendants leased from us the”Plaintiffs” the Subject Property

at the monthly rate of Three Thousand five Hundred Pesos (P3,500.00).

A copy of aforementioned Contract Lease is attached hereto and made integral parts
hereof Annex “E”

7. Since then, Defendants has been religiously paying said monthly rentals to us the
”Plaintiffs”.

8. However, starting October 1, 2015 and up to present, Defendants failed to pay the
agreed monthly rentals.

A Demand Letter was mailed to the Defendants reminding the agreement that was
made on January 3, 2016 of an extension given until March 30, 2016 to vacate the
Subject Property. As well as demanding payment of the monthly arrears that was left
unpaid for 6 consecutive months amounting to Twenty One Thousand Pesos
(P21,000.00).

A copy of aforementioned Demand Letter is attached hereto and made integral parts
hereof Annex “F”.

9. On March 31, 2016, We the “Plaintiffs” filed a complaint with the Barangay in connection
with the Defendant’s failure to pay the accrued rentals and refusal to vacate the
property. Despite several scheduled meetings with the Barangay, the Defendants
refused to pay the accrued rentals and to vacate the Subject Property. Hence, the
Barangay issued the Certificate to File Action (in court) dated May 20, 2016.

A copy of the said Certificate to File Action is made integral part hereof and attached
herewith Annex “G”.

10. Despite formal demand and notice to vacate duly made, Defendants refused to pay the
unpaid lease rentals and to vacate the Subject Property. Defendants continues to
occupy the Subject Property without Our consent, to the latter’s extreme damage and
prejudice.

11. Finally, Defendants’ refusal to yield possession over our Subject Property after
withdrawal of Our consent, has caused us to suffer material injury by way of actual
damages in the amount of P21,000.00 representing rental arrears as of the date of the
aforesaid demand letter, and the loss of P3,500.00 monthly thereafter representing the
monthly rent.

PRAYER
WHEREFORE, in view of all the foregoing, it is respectfully prayed for this Honorable
Court that judgement be rendered.

1. Ordering the Defendants and all persons occupying the Subject Property and claiming
rights under them to vacate the Subject Property and deliver the lawful possession
thereof to us the “Plaintiffs”.

2. Ordering the Defendants to pay us the “Plaintiffs” the amount of Twenty One Thousand
Pesos (P21,000.00) representing rental arrears from October 1, 2015 to March 30,
2016, plus P3,500.00 a month starting April 1, 2016, until Defendants and all persons
claiming rights under them finally vacate the premises, plus legal rate of interest.

3. Ordering the Defendants to pay the costs of this suit.

IN WITNESS WHEREOF, We have hereunto set our hands this _____day of

__________________, 2019 in the City of Caloocan City.

_____________________________ ____________________________
VERONA C. SADIASA MERLINA C. SADIASA
Plaintiff Plaintiff

REPUBLIC OF THE PHILIPPINES)

CITY OF ____________________ )

SUBSCRIBED AND SWORN to before me, in the Municipality of

_________________________ this ________day ______________________2019.

NOTARY PUBLIC

Doc. No.____:
Page No.____:
Book No.____:
Series of 2019