REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT OF CITIES

City of Lucena
Branch 2

LUCK DAWN,
Plaintiff,

SPECIAL CIVIL ACTION

NO. 57845
-versus- FOR: UNLAWFUL DETAINER

CON VID
Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and

unto this Honorable Court, respectfully avers that:

(1) The plaintiff, LUCK DAWN, is of legal age, Filipino citizen, single, with
residence and postal address at 123 Ludwig St., Forbes Park, Lucena
City, Quezon;

(2) The defendant, CON VID, is of legal age, Filipino citizen, single, with
residence and postal address at 125 Ludwig St., Forbes Park, Lucena
City, Quezon, where they may be served with summons and other court
processes;

(3) The plaintiff is the owner of the residential house and lot situated at 125
Ludwig St., Forbes Park, Lucena City, which is presently being leased on
a month-to-month basis by the defendant by virtue of a lease contract,
copy of which is attached hereto and made part hereof as Annex “A”;

(4) Under said contract, the defendant should pay rent in the amount of Three
Thousand (3,000.00) until the expiration of the lease contract on
December 31, 2019;

(5) The lease contract, Annex “A”, has expired and the defendant is
continuously residing of the house and lot of the plaintiff and in
possession of the property without paying anything to the plaintiff;

(6) Despite repeated demands, the last demand on April 20, 2020 through a
letter duly received by the defendant on said date, the latter without any
justifiable cause or reason refused and continuously refuses to vacate the
premises. Copy of the letter of demand showing receipt of the same by the
defendant is attached hereto and made part hereof as Annex “B”;

(7) 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 as
attorney’s fees;
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

unto this Honorable Court that, after hearing, judgment be rendered
ordering the defendant:

(a) Judgement be rendered ordering the defendant to vacate the premises

and peacefully return the same to the plaintiff;

(b) Defendant be ordered to pay and deposit the total amount due of
Twenty Four Thousand (24,000.00) from October 1, 2019 until May 2020,
and until such time the lessee vacated, as rental for the use and
occupancy of the premises from which he is being ejected with legal
interests;

(c) To indemnify damages representing loss of earnings and future

earnings;

(d) To pay the plaintiff the cost of the suit;

(e) Such other relief just and equitable under the premises is likewise
prayed for.

City of Lucena.May 20, 2020.

CATINDIG LAW OFFICE

Governor Guinto Street, Brgy. IX,
Lucena City, Quezon Province

By:

ATTY. PATRICK JUSTIN J. CATINDIG

Counsel for the Plaintiff
Roll of Attorney No. 99874
IBP No. 12345/5-9-17/ Quezon
PTR No. 87654/1-20- 17/ Quezon
MCLE Comp. No. IV-4789, 10/26/2020
Republic of the Philippines)
Lucena City )S.S.

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, LUCK DAWN, of legal age, Filipino, a resident of 123 Ludwig St., Forbes
Park, Lucena City, Quezon, after having been duly sworn in accordance
with law, depose and state that:

1. I am the petitioner in the above-stated case;

2. I cause 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 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
face within five (5) days therefrom to this Honorable Court.

LUCK DAWN
Affiant
IN WITNESS WHEREOF, I have hereunto affixed my signature this
20th of May 2020, in the City of Lucena.

SKY KURTIS DE CASTRO KENNETH DE LOS REYES

UMID – 0111-762189-1 UMID – 0003-197651-2

SUBSCRIBED AND SWORN to before me this 20th day of

May2020 at Lucena City, affiant exhibiting to me her Community Tax
Certificate No. 25467 issued on February 3, 2020 at Lucena City.

ATTY. PATRICK JUSTIN J. CATINDIG

Notary Public
Roll of Attorney No. 99874
IBP No. 12345/5-9-17/Quezon
PTR No. 87654/1-20- 17/ Quezon
MCLE Comp. No. IV-4789, 10/26/2020

Doc. No.57;
Page No.15;
Book No.1;
Series of 2020.