REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

City of Tuguegarao, Province of Cagayan
Branch 06

Makati Medical Center, Incorporated,

S&R Membership Shopping, Incorporated,

Nurses and Doctors of Makati Medical Center, and

Staff of S&R Membership Shopping Incorporated

Plaintiffs,
CIVIL CASE No. ______
- versus - FOR: DAMAGES

Aquilino Pimentel III and

Kathryna Pimentel
Defendants.
x-----------------------------------x

COMPLAINT

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

1. That the plaintiff, Makati Medical Center, Incorporated (MMC for Brevity), is a
tertiary-level hospital and a privately-owned corporation duly-registered and incorporated
under Philippine law, and with business address at Bankal Street, Makati City, Metro
Manila;
2. That the defendant, Name of Defendant, is of legal age, Filipino citizen, single, and a
resident of No. 25 Walangdaan St., Wonder City, Philippines;
3. That the plaintiff is the owner of a land over which an apartment had been constructed
located in No. 24 Walangdaan St., Wonder City, Philippines;
4. That being relatives, the plaintiff has allowed defendant to use the apartment and the land
owned by the former starting October 3, 2016 until such time when defendant would be able
to put up and build her own house in her own land and while no tenant is leasing the said
property.
5. That on April 11, 2017, 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 Annex “A”;
6. That despite said letter of demand which was repeated by oral demands, the defendant
failed and still refused to vacate the premises;
7. 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 subject premises;

2. To pay damages for illegal use and lost income computed from the date of first demand
until the defendant finally vacates the premises; 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.

Wonder City, Philippines, May 9, 2017.

Atty. Antonio B. Maayo

Counsel for Plaintiff
PTR No. 8884567, Wonder City, 1/2/17
IBP OR No. 688821, Wonder City, 1/2/17
Attorney’s Roll No. 11882
MCLE Compliance Certificate No. IV-0025415,
Pasig City, 1/2/17

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

I, Name of Plaintiff, of legal age, Filipino, after having been sworn, in accordance with law,
hereby depose and state that:

1. I am the 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.

Name of Plaintiff
Affiant
 SUBSCRIBED and SWORN TO before me this 21st day of April 2017 at
_______________, Philippines, affiant exhibiting to me her SSS ID with ID No.
______________ issued by the Social Security System, as competent evidence of her
identity, and she personally acknowledged to me that the foregoing “Petition” is her free
and voluntary act and deed. Machine copy of this SSS ID is hereto attached.

Atty. Karmila D. Abogada

Notary Public
PTR No. 1234567, Iloilo 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 20______.