Republic of the Philippines

Third Judicial Region

Municipal Trial Court in Cities
City of Meycauayan, Bulacan

XYZ CORPORATION, as
represented by its President,
X,

Plaintiff,

CIVIL Case No. ______________

-versus- For: Unlawful Detainer

ABC MULTI-PURPOSE
COOPERATIVE, as represented
by its Chairperson, A,
Defendant.

COMPLAINT

PLAINTIFF, assisted by the undersigned counsel, unto this Honorable Court,

most respectfully states that:

1. Plaintiff, is a domestic private corporation duly organized and existing under

Philippine laws, engaged in the business of leasing real properties, and with
business and office address at 1st Floor, XYZ Building, Bancal, Meycauayan
City, Bulacan where it may be served with notices and other court processes;

2. Plaintiff is represented at the instance by its President, X, as evidenced by a

Secretary’s Certificate which is hereto attached as ANNEX “A”;

3. Defendant is a duly organized cooperative existing under Philippine laws, as

represented by its Chairperson, A and with business and office address at 7th
Floor, Unit 702, XYZ Building, Bancal, Meycauayan City, Bulacan where it may
be served with summons and other court processes;

4. Plaintiff is the registered owner of a commercial building covered by TCT No.

T-1111 located at XYZ Bldg, Meycauayan City, Bulacan consisting of One
Thousand Five Hundred (1500) square meters more or less. A copy of
Transfer Certificate of Title No. T-1111 is herein attached as ANNEX “B”;

5. On 10 March 2018, plaintiff and defendant entered into a Contract of Lease

over Units 702 and 703 of the above-mentioned property owned by the
plaintiff at the agreed rental rate of Twenty Thousand Pesos (Php.20,000.00)
and Five Thousand Pesos (Php5,000.00) per month, respectively for a period
 of two (2) years commencing on 15 March 2018 and ending 15 March 2020
and the rents are payable on or before the 16th day of every month. Copies of
the said Contract of Lease are hereto attached as ANNEX “C” and ANNEX “D”
respectively;

6. Defendant then occupied the subject properties and paid the corresponding
advance rental and deposit stipulated in the Contract of Lease;

7. However, the defendant failed to pay its monthly rental for the months of
January to May 2019. Plaintiff then demanded payment for the rentals but
the defendant failed and continuously failed to settle their account;

8. On 30 July 2020, plaintiff sent final demand letters demanding the defendant
to vacate the premises and to pay the rental arrears. The demand letters
were personally served by their lawyer and was received by a certain C, an
employee of the defendant. A copy of the received demand letter is hereto
attached as ANNEX “E”;

9. Despite the receipt of the final demand letter, defendant still failed to settle
their unpaid rentals and refused to surrender the possession of said property
without any valid or justifiable reason;

10. Several efforts were made but plaintiff and defendant failed to amicably
settle. 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;

11. In view of the defendant’s wanton, malevolent and unjust refusal to vacate
the subject property, the plaintiff is being deprived of the use and enjoyment
of her property for which defendant should be adjudged to pay a reasonable
rental from demand until actual return of possession in the amount of Php.
25,000.00 per month; and

12. Due to the action of the defendant who is in gross and evident bad faith in
refusing to satisfy the plaintiff’s plainly valid, just and demandable claim,
attorney’s fees, acceptance fees and appearance fees per hearing should be
paid to the plaintiff.

PRAYER

WHEREFORE, it is respectfully prayed that judgment be rendered in favor of the

plaintiff and against the defendant, ordering the latter, as follows:

1. Ordering the defendant and all persons claiming rights under him, to
VACATE the commercial spaces located in Meycauayan, Bulacan;

2. Ordering the defendant to PAY the plaintiff the rental arrears at the rate of
P25,000.00 per month from January 2020, until the subject property is
vacated; and
 3. Ordering defendants to pay plaintiff the amount of P20,000.00 for and as
attorney’s fees as well as the costs of suit.

Other reliefs just and equitable in the premises are likewise prayed for.

City of Meycauayan, Bulacan. 11 September 2020

DE GUZMAN AND ASSOCIATES

Counsel for the Plaintiff
nd
2 Floor, Peninsula Building
1126 JP. Rizal Street, Guinhawa
City of Meycauayan, Bulacan

MICHAELA DE GUZMAN
Roll of Attorneys No. _________
PTR No. ______. __(date)__
IBP LRN ______. __(date)__
City of Malolos, Bulacan
MCLE Compliance No._________. __(date)__
Mobile No. ______________
E-mail Address: ______________________

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, X, of legal age, after having been duly sworn in accordance with law, hereby
depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

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 of copies of documents and
records in my possession;

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.
X
Affiant

SUBSCRIBED AND SWORN to before me this 11th day of September at

Meycauayan City, Bulacan, affiant exhibiting to me his Driver’s License ID No. C05-
48-021197 issued on 25 January 2020 at Meycauayan Bulacan as competent
evidence of his identity.

WITNESS MY HAND AND NOTARIAL SEAL on the day, year and place first
above-written.

ATTY. TONI CASSANDRA B. SANTOS

Notary Public for and in the Province of Bulacan
Until December 31, 2020
2nd Floor, Diamond Building, Bonifacio St.,
Meycauayan City, Bulacan
Roll of Attorney No. 122497
IBP No. 112496/09.09.19
PTR No.1050198/02.11.97/Meycauayan, Bulacan
MCLE Compliance No.VI 0000548/08.24.96
santos.tcb@gmail.com
09352771108

Doc No. _________;

Page No. ________;
Book No. ________;
Series of _________.