REPUBLIC OF THE PHILIPPINES

METROPOLITANT TRIAL COURT

QUEZON CITY

Branch 17

NICOLE DOMINIQUE N.IBAY,

Plaintiff,

CIVIL CASE No. 061718995

FOR: Unlawful Detainer

-vs-

JUAN DELA CRUZ,

Defendant.

x-----------------------------------x

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this

Honorable Court, MOST RESPECTFULLY AVERS:

1. That the plaintiff, NICOLE DOMINIQUE N. IBAY, of legal age, Filipino,

single, residing 78 B Gen. Segundo St., Brgy., Sta., Cruz Heroes Hill Quezon

City;

2. That the defendant, SELENA GOMEZ, of legal age, Filipino, single residing

78 A Gen. Segundo St., Brgy., Sta., Cruz Heroes Hill Quezon City and

existing under the laws of the Philippines,;

3. That defendant Juan Dela Cruz was occupying the said property for more

than the agreed upon length of leased as evidenced by pertinent documents

like personal notice to vacate and pay due rentals herein attached. (EXHIBIT

“A” );

4. That on August 31, 2018, the plaintiff and the defendant entered into a

contract of lease of the aforementioned property to be paid as follows:

September 1, 2018 – Twenty Thousand pesos (PHp 20,000.00), one month

thereafter - Twenty Thousand pesos (PHp 20,000.00), Every thirtieth day of

the succeeding month for the balance

5. That after the contract of lease has been perfected, the defendant, who has

been leasing the property for one year, whose contract of lease has already

expired last September 1, 2019 as evidenced by such contract (Exhibit “B”)

but was still found to be occupying the said property should be evicted by the

plaintiff immediately;

6. That he should immediately vacate and pay due rentals of the said rentals of

the said property;

7. That the defendant refused, and continues to refuse, vacate and pay due

rentals;
8. That the plaintiff, personally gave the defendant a demand letter on

September 2, 2019 and continuously repeated to demand orally that the

defendant to comply with his obligation;

9. By reason of the failure of the defendant to comply with his obligations to

vacate and pay due rentals, the plaintiff was compelled to file this complaint.

WHEREFORE, premises considered, it is most respectfully prayed unto

this Honorable Court that judgment be rendered ordering the defendant:

1. To vacate the said property;

2. To pay due rentals; and

3. To pay the plaintiff the cost of the suit.

Plaintiff likewise prays for such other reliefs that are deemed just and

equitable under the premises.

Quezon City, Philippines, September 12, 2019.

 Atty. Maria Makiling

Counsel for Plaintiff

PTR No. 8884567, Quezon City, 4/7/19

IBP OR No. 688821, Quezon City, 4/7/19

Attorney’s Roll No. 11882

MCLE Compliance Certificate No. IV-

0025415,Quezon City, 4/7/16

VERIFICATION/CERTIFICATION OF NON-FORUMSHOPPING

I, NICOLE DOMINIQUE IBAY, of legal age, Filipino, single, resinding at 78B gen

Segundo st. brgy. Sta. cruz heroes hill sudb. Quezon City, after having been

sworn, in accordance with law, hereby depose and state that:

1. I am 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.

NICOLE DOMINIQUE IBAY

Affiant
 SUBSCRIBED and SWORN TO before me this 12TH day of September

2019 at the City of Manila, Philippines, affiant exhibiting tome his SSS ID with ID

No. 232323 issued by the Social Security System, as competent evidence of his

identity, and she personally acknowledged to me that the foregoing “Petition” is

his free and voluntary act and deed. Machine copy of this SSS ID is hereto

attached.

Atty. Jessica Parker

Notary Public

PTR No. 1234567, Manila City, 1/2/17

IBP OR No. 654321, Iloilo City, 1/2/17

Attorney’s Roll No. 11122

MCLE Compliance Certificate No. IV-

0025415,Pasig City, 1/2/17

Doc No. _____;

Page No. _____;

Book No. _____;

Series of______.