CHAPTER III RULE 7: PARTS AND CONTENTS OF A PLEADING COMES NOW, the plaintiff, and unto this Honorable Court, most respectfully avers: 1. That plaintiff is of legal age, Filipino citizen, with Postal address at #1136-A A. Maceda Street, Sampaloc, Manila; 2. That defendant Y, of legal age, Filipino citizen, with Postal address at No. 205 Rafael Compound, Paseo de Animales, Santolan, Pasig City, where they may be served wth summons and other processes by this Honorable Court; 3. That the subject lot/premises was originally owned Sy A, B, C, and D as evidenced by their Transfer Certificate of Title Nos. PT-116888 and PT-116887 under their mames. Copy of Transfer Certificate of Title Nos. PT- 116888 and 116887 are hereto attached as Annexes “A” and “B’ hereof; 4. That the defendant has been occupying the said Premises at No. 200 Rafael Compound Paseo De Animales, Santolan, Pasig City for more than ten (10) years by mere tolerance of the original registered owners; 5. That on March _, 2011, one of the registered owner, D, sold his one-third (1/3) share over the said parcel of land to the plaintiff, as evidenced by the Deed of Absolute Sale which is hereto attached as Annex “C” hereof; 6. That as the new owner, plaintiff sent a demand letter to the defendants demanding from the latter to vacate the premises and to pay a reasonable compensation for the use of the said premises in the amount of P10,000.00 per month. Copy of the demand letter personally served to the defendants is hereto attached as Annex “D” hereof; 7. That despite repeated demands orally and in writing, defendants refused and continuously failing to vacate the said premises and pay the amount of P10,000.00 as compensation for the reasonable use of the subject premises to the damage and prejudice of herein plaintiff; 499500 CIVIL PROCEDURE: A GUIDE FOR THE BENCH AND THE BAR 8. That as aresult of the unwarranted and unjustifiable refusal of the defendants to vacate the aforesaid premises/ parcel of land and to pay reasonable compensation for the use of the same, plaintiff suffered sleepless nights, serious anxiety in which he should be awarded the amount of P100,000.00 as moral damages, and to set an example to the public plaintiff should be awarded exemplary damages in the amount of P100,000.00. WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that, after hearing, judgment be rendered as follows: 1. Ordering the defendants, and all persons claiming right under them to vacate the subject premises/portion of the lot; 2. Ordering the defendants to pay the amount of P10,000.00 per month as compensation for the reasonable use of the subject portion of the lot/premises until they finally vacate the said lot/premises; 3. Ordering the defendants to pay the plaintiff the amount of P100,000.00 as moral damages, and P100,000.00 as exemplary damages; 4. Ordering the defendants to pay the cost of suit. Such other relief as may be deemed just and equitable under the premises are likewise prayed for Manila for Pasig City, March __, 2020.