COMPLAINT

____________________, MOST RESPECTFULLY STATES THAT; COMES NOW, the plaintiff together with
the undersigned counsel to this most honorable court

1. The Plaintiff is of legal age, married and a resident of _______________________. The Defendant is
likewise of legal age, married and temporary residing at _____________________

2. The Plaintiff is the owner of the two-storey house unit located at the Petersville Subdivision, Baguio
City, and having the residential address of PV 123 as evidenced by pertinent documents like tax
declaration and deed of sale. ( EXHIBIT “A” )

3. The Defendant is the lessee of the house unit that is owned by the Plaintiff as evidenced by the
written contract of lease that both parties signed. (Exhibit “B”)

4. The Plaintiff and the Defendant came up with a written agreement of Lease on June 26, 2007, which
they both agreed upon and was duly signed by the two parties as shown in their contract of lease.
(Exhibit “B”)

5. Item No. 16 of the contract which the defendant signed expressly provides that he will only be
occupying the property for one (1) year, after which, he will vacate the house when that term expires.
(Exhibit “B”)

6. The contract also provides that the defendant should also take care of the property and its premises”
with the utmost diligence”.

7. On June 28, 2008, the plaintiff, after returning from Japan, was surprised to discover that the
defendant did not vacate the property as he expected. Worse, he installed a “sari-sari store” in the
original building structure of the house unit.

8. The plaintiff confronted the defendant about it but the defendant claimed that it was a “DEED OF
SALE” which they signed and not a “CONTRACT OF LEASE” and therefore, the defendant is the new
owner of the house unit.

9. On August 20, 2008, after continuous demands, the defendant constantly refuses to vacate the house
unit and even invited relatives to stay with him.

10. The defendant willfully and maliciously violated the agreement which they mutually agreed upon,
and which the defendant signed.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that
judgement be rendered in favor of the plaintiff and that after judgement; a. The defendant shall vacate
the house unit owned by the plaintiff. b. The defendant shall be ordered to pay P 120, 000 for the
Attorney’s Fees. Such other reliefs and remedies under the premises are likewise prayed for.
_________________, Philippines, this ____ day of _________ 20__.
 ______________________
Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Rm. 4 2/F Baguio Boating Center
180 Burnham Lake, Baguio City