REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT IN CITIES

Quezon City
Branch 1

JUAN B. DEL MUNDO,

Plaintiff,
CIVIL CASE No. 12345-2020
For: Ejectment
versus

JOSE C. REYES,
Defendant.
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COMPLAINT

Unto this Honorable Court, Plaintiff through the undersigned

counsel, most respectfully avers:

1. That the plaintiff, JUAN B. DEL MUNDO, is of legal age, a Filipino

citizen, and a resident of 143-A Brgy. Holy Spirit, Quezon City,
Philippines;

2. That the defendant, JOSE C. REYES, is of legal age, a Filipino citizen,

and a resident of 101 Brgy. Holy Spirit, Quezon City, Philippines;

3. That the plaintiff is the owner of a parcel of land over which an

apartment had been erected, located at 244 Brgy. Holy Spirit,
Quezon City, Philippines;

4. That being best friends, the plaintiff has allowed defendant to use
the aforesaid land and apartment owned by the former starting
October 31, 2019 until such time when defendant would no longer
need the same and while no tenant is leasing the property in issue;

5. That on January 23, 2020, the plaintiff sent the defendant a letter
of demand to vacate the apartment which was received by the
latter as shown in the registry return receipt, hereto attached as
Exhibit A;

6. That despite said demand and the subsequent oral demands, the
defendant failed and still refused to vacate the premises;
 7. That by reason of the failure of the defendant to vacate the
premises, 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 premises;