LEGAL WRITING (JDLW)

Saturday, 10:00am - 12:00nn

Atty. Jules R. Valdez, CPA

EJECTMENT CASE

Facts:

1. Juan Dela Cruz is the owner of a residential house and lot covered by TCT No.
123456-R located in #69 Hobart St., ABC Homes, Las Pinas City. She is residing in 456
Casa Pura, Brgy. Culiat, Quezon City.

2. The aforementioned property was leased to Eva Carino Brutal since 2009 by a lease
contract from January 1, 2009 to December 31, 2009. Unfortunately, the contract was
not renewed since it expired but the same was continuously being rented by Ms. Brutal.

3. On Dec. 1, 2019, Ms. Dela Cruz decided to sell the property to Andrew F. Medina
and they executed a Deed of Sale. Since Mr. Medina became the new owner, he
demanded Ms. Brutal to vacate the property.

4. Ms. Carino, however, refused to vacate the said property since she claims that she
has the right of first refusal to the property and will invalidate the deed of sale if Mr.
Medina will file an ejectment case because she already obtained a prior right against
him.

Instructions:

In preparation for an ejectment case, please prepare a Complaint and Answer based on
the aforementioned facts.

You may use existing laws and jurisprudence in preparing the same.