REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Davao
Branch 1
MONKEY D. LUFFY,
Plaintiff,
-versus-
Civil Case No. 111-62-8488
For: Complaint Unlawful
Detainer
MONKEY D. DRAGON,
Defendant.

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

COMPLAINT

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

1. That the plaintiff, MONKEY D. LUFFY, is of legal age, Filipino citizen,

single, with residence and postal address at 584 NHA Buhangin, Davao City;

2. That the defendant, MONKEY D. DRAGON, is of legal age, Filipino citizen,

single, with residence and postal address at 796 NHA Maa, Davao 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 674 Condo Homes, Matina, Davao City ;

4. By virtue of a contract of lease, the plaintiff leased unto the defendant the
aforesaid apartment for a consideration of P10,000.00 a month as rental to be
paid within the first ten (10) days of each month starting November 14, 2018;

5. The defendant failed to pay the agreed rental for several months starting June
14, 2019 up to the present;

6. On July 14, 2019, 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 P10,000.00.

WHEREFORE, premises considered, it is most respectfully prayed unto this

Honorable Court that, after hearing, judgment be rendered ordering the
defendant:
a) To vacate the subject premises;
b) To pay the amount of P10,000.00 per month as compensation for
the reasonable use of the subject premises until they finally
vacate the said premises;
c) To pay the plaintiff the cost of the suit.

City of Davao, February 2, 2020.

GRIDLIN A. MATILAC
Counsel for Plaintiff
Until December 31, 2021
Attorney’s Roll No. 10772
PTR No. 7862245 B; 01-02-20; Davao City
IBP O.R. No. 024454; 01-02-20; Davao City

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF DAVAO DEL SUR) S.S
IN THE CITY OF DAVAO………..)
X…………………………………….X

VERIFICATION AND CERTIFICATION

I, MONKEY D. LUFFY, of legal age, after having been duly sworn in

accordance with law, depose and state that:
1. I am a petitioner in the above-stated case representing the republic of
the Philippines;
2. I caused the preparation of the foregoing petition;
 3. I have read the contents thereof and the facts stated therein are true
and correct of my personal knowledge and/or on the basis true and
authentic records.
4. I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has
been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that fact
within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signatures this 2nd

day of February 2019, at Davao City, Philippines.

MONKEY D. LUFFY
Affiant

SUBSCRIBED AND SWORN to before me this 2nd day of February 2020 at

NHA Davao City affiant exhibiting to me his PRC ID. No. 6123 as competent
proof his identity, personally signed the forgoing affidavit and acknowledged
that he executed the same.
WITNESS MY HAND AND SEAL this 2nd day of February 2020 in Davao
City, Philippines.

NOTARY PUBLIC
Doc. No. 46;
Page No. 10;
Book No. 01;
Series of 2020.