REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
QUEZON CITY

ASHLEY G. BENSON, Civil Case No.: 002

Plaintiff, For: Unlawful Detainer

-versus-

EMMA C. WATSON,
Defendant.
x-------------------------------------x

COMPLAINT

Plaintiff, through undersigned counsel, unto this Honorable Court respectfully

alleges that:

1. Plaintiff is of legal age and a resident of No. 7, West Aguila St., Green Cross
Subdivision, Quezon City, while defendant is of legal age and a resident of No. 9,
West Aguila St., Green Cross Subdivision, Quezon City, where he may be served
with summons;

2. Plaintiff is the owner of a house and lot locate at No. 9, West Aguila St., Green
Cross Subdivision, Quezon City;

3. On May 1, 2016, defendant leased the said house and lot from the plaintiff for a
period of two (2) years starting on the said date, at a monthly rental of
P50,000.00 a month, payable within the first five (5) days of each month;

4. By virtue of the said lease, possession of the said house and lot was delivered to
the defendant starting May 6, 2016;

5. However, defendant defaulted in the payment of the monthly rentals for six (6)
months, from January 1, 2017 to June 30, 2017;

6. Due to the default of the defendant in the payment of his rent, the plaintiff,
through undersigned counsel, sent him a letter dated July 10, 2017, terminating
his lease and demanding that he vacate the leased premises and pay his rentals
in arrears within five (5) days from receipt of the said letter; a copy of the said
letter is hereto attached as Annex “A” hereof;
 7. Defendant received the said letter on July 15, 2017, as shown by his signature at
the bottom of Annex “A” hereof, but he failed and refused, and until the present
continues to fail and refuse, without justifiable cause, to vacate the premises and
pay his rentals in arrears;

8. Due to the refusal and/or failure of the defendant to comply with the plaintiff’s
plainly just and valid claim, plaintiff was compelled to file this complaint, and to
engage the services of legal counsel for a fee of P50,000.00, for which defendant
should be held liable;

WHEREFORE, it is respectfully prayed that, after due hearing, judgment be rendered:

a. Ordering the defendant to vacate the house and lot located at No. 9, West
Aguila St., Green Cross Subdivision, Quezon City, and surrender possession
thereof peacefully to the plaintiff;

b. Ordering the defendant to pay the plaintiff rentals in arrears at the rate of
P50,000.00 a month from January 1, 2017 until the time that he actually
vacates the leased premises;

c. Ordering the defendant to pay the plaintiff the sum of P50,000.00 as

attorney’s fees; and
d. Ordering the defendant to pay the costs of suits.

Plaintiff prays for such other and further reliefs as may be just and equitable
under the premises.

Quezon City, November 6, 2017.

(sgd.)ATTY. MANUEL C. FRANCISCO

Unit 6, Rose Bldg., Quezon City
IBP No. 123456; 01/12/16
PTR No. 123456; 04/23/16
Roll No. 602697; 3/21/16
MCLE No. V – 002976; 8/16/16
MCLE No. VI – 012978; 1/23/17

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, Ashley G. Benson, after being duly sworn hereby depose and state:

1. That I am the plaintiff in the above-entitled case;

 2. That I have not initiated any case involving the same issues before any other
court or administrative body, and;

3. That if I should hereafter learn about the pendency of another case involving the
same issues in another court, tribunal or administrative body, I will notify this
Honorable Court within five (5) days from thereon.

Quezon City, Philippines; November 6, 2017.

In witness whereof, I have hereunto set my hands this 6th

day of November 2017, in the city
of Quezon, Philippines.

(sgd.)ASHLEY G. BENSON
Affiant

JURAT

SUBSCRIBED and sworn to before me the notary public for Quezon City, this 2nd
day of November, 2017 in the City of Quezon. Affiant is identified through his
Professional Driver’s License with License No. 0012345 issued on June 30, 2017 at
Quezon City.

(sgd.) ATTY. SOFIA SANTOS

Unit 1, Flores Building, Quezon City
IBP No. 123456; 01/12/16
PTR No. 123456; 04/23/16
Roll No. 602697; 3/21/10
MCLE No. V – 002976; 8/16/16

NOTARY PUBLIC

Doc. No. 01;

Page No.56;
Book No.10;
Series of 2017