Republic of the Philippines

FOURTH JUDICIAL REGION

MUNICIPAL CIRCUIT TRIAL COURT
Taal Batangas

SUSAN ROXAS
Plaintiff,

Civil Case No. 55121

For: Unlawful Detainer
SPOUSES JUAN and STELLA BERNABE
Respondents.

COMPLAINT

PLAINTIFF, by counsel, and unto this Honorable Court, most respectfully allege:

1. That the Plaintiff is of legal age, Filipino, with residence and postal address at Brgy Butong Taal
Batangas where she may be served notices and other court processes;

2. That the Respondents are of legal ages, married, Filipino, with residence and postal address at Brgy
Butong Taal Batangas;

3. That the Plaintiff is the absolute owner of the 500 sqm lot under title Lot No 123 located at Brgy
Butong Taal Batangas which was acquired from SPS JOSE and Maria Castillo and now occupied by the
respondent; attached herein is the transfer certificate of title as annex A

4. That By mere tolerance of the previous owner and plaintiff, the lot came into possession and
occupation of the Respondent ;

5. That upon acquisition by the plaintiff of the said lot on August 2012, it was orally agreed by the
plaintiff and the respondent that upon determination of the former of the use of the lot, the latter shall
vacate the property;

6. That several oral demands were made but the respondent refused to leave the premises of the
property and On February 17, 2020, a demand to vacate the property were made and a 30-day grace
period was given but the respondents did not heed to the letter of the plaintiff; attached herein as
annex B

6. That until now the respondents still refuse to vacate the property;

7. Thus, respondent is unlawfully withholding possession of the subject property from the plaintiff
despite last and final demand, to the damage and prejudice of the plaintiff;

8. That Before filing this complaint, the dispute has been referred to the Lupong Tagapamayapa of Brgy
Butong Taal Batangas but no amicable settlement was made reached. Attached herein is the certificate
to file action as Annex C
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that after due
notice and hearing, judgment be rendered in favor of Plaintiff:

1. For the restitution of the abovementioned property;

2. To pay the cost of the suit

Such other relief prayed for that may be granted in this suit.