FORM_18-COMPLAINT

Republic of the Philippines

MUNICIPAL TRIAL COURT
Third Judicial Region
Branch IV
Angeles City

BARTHOLOMEW ALLEN,
Plaintiff,
SCA No. R-4444
- versus -
FOR: Ejectment (Unlawful
Detainer)
OLIVER QUEEN,
Defendant,
x--------------------- -x

COMPLAINT

COMES NOW PLAINTIFF BARTHOLOMEW ALLEN, by

counsel, and to this Honorable Court, respectfully alleges:

1. That the plaintiff, is of legal age and resident of #111 St., Jude,
Brgy. Alfonso, Angeles City, Pampanga, Philippines; while the
defendant is also of legal age, with residence and post office
address at 19-30 Yvette St. Essel Park Subdivision, Brgy.
Telabastgan, Angeles City, Pampanga, Philippines;

2. That the plaintiff is the absolute owner and lessor of that

certain building located in 19-30 Yvette St. Essel Park
Subdivision, Brgy. Telabastgan, Angeles City, Pampanga,
Philippines, and now leased and occupied by the defendant;

3. That the defendant leases and occupies the said building

under the express obligation of paying a rent of TWENTY
FIVE THOUSAND PESOS (P25,000.00), Philippine
Currency, a month; payable in advance within the first five (5)
days of each month;

4. That the defendant has not paid the rents for the said building
for the month of January until March of the current year;

5. That furthermore, the defendant has failed to comply with the

conditions of his lease, namely: The monthly rental shall be
TWENTY FIVE THOUSAND PESOS (P25,000.00), Philippine
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FORM_18-COMPLAINT

Currency, to be paid by the LESSEE at the house of the

LESSOR on or before the fifth (5th) day of each any every
month, plus one per centum (1%) surcharge per month for the
payment of rentals made after the 5th day of the month due. It
is expressly agreed and understood that the payment of the
rental herein stipulated shall be made without the necessity of
express demand and without delay on any ground
whatsoever;

6. That the plaintiff has demanded of the defendant several

times to vacate the above premises and to pay his back rents,
now amounting to SEVENTY FIVE THOUSAND PESOS
(P75, 000.00) Philippine Currency, the last demand for
payment having been made on him personally and in writing
on March 27, 2020 or more than seven days before the filing
of this complaint.

PRAYER

WHEREFORE, premises considered, plaintiff respectfully prays

from this Honorable Court:

1. Ordering the defendant to:

a. That the restitution of the above-mentioned premises be
granted to plaintiff;
b. For the payment of SEVENTY FIVE THOUSAND PESOS
(P75,000.00) Philippine Currency, representing the arrears of
rent now overdue, with legal interest from the filing of this
complaint; and
c. The costs of suit.

2. Plaintiff respectfully prays for such other reliefs as may be just

and equitable in the premises.

Respectfully submitted.

Angeles City, Philippines, 03 April 2020.

ATTY. RAYMOND G. RONQUILLO

Counsel for Plaintiff
RONQUILLO & ASSOCIATES LAW OFFICE
Rm. 404 RGR Bldg., McArthur Hi-way, Salapungan, Angeles City
IBP Lifetime No. 000000/Pampanga
PTR No. 0000000/January 02, 2020/Angeles City
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FORM_18-COMPLAINT

Supreme Court Roll of Attorney’s No. 00000

MCLE Compliance No. V–0000000/October 01, 2019

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, Bartholomew Allen, Filipino, of legal age, after been duly

sworn, depose and state that:

1. I am the Plaintiff in the foregoing Complaint for Unlawful

Detainer.
2. I caused the preparation of the foregoing Complaint which I
have read and understood.
3. I hereby affirm that all factual allegations contained in the said
Complaint are true and correct of my own personal knowledge
and belief, as well as true and correct basis of authentic
documents and records in my possession.
4. I further certify that I have not commenced any other action
involving the same issues before the Supreme Court, Court of
Appeals or any division thereof or any tribunal or agency; and
to the best of my knowledge no such action is pending before
the Supreme Court, Court, Court of Appeals or any division
thereof or any tribunal or agency.

In the event that any action involving the same should be made
known, I hereby bind myself to report the same within five (5) days from
knowledge thereof to this Honorable Court.

IN WITNESS WHEREOF, I hereunto set my hand this 3rd day of April

2020 at Angeles City, Philippines.

BARTHOLOMEW ALLEN
Plaintiff

SUBSCRIBED AND SWORN to before me, this 3rd day of April

2020, in Angeles City, Philippines, by the following whom I have
identified through competent evidence of identity and who exhibited to
me the same as follows:

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FORM_18-COMPLAINT

PERSONS COMPETENT EVIDENCE OF IDENTITY

BARTHOLOMEW ALLEN UMID No. CRN-0062-1245678-9

Date of Issue: N/A

Doc. No. 17; ATTY. RENEE MIRIELLE G. DELA CRUZ

Notary Public for Angeles City
Page No. 04; DELA CRUZ & ASSOCIATES LAW OFFICE
Book No. I; Rm. 209 PS Bldg., McArthur Hi-way, Salapungan,
Angeles City, Philippines
Series of 2020. Roll No. 00000, June 4, 2017
Commission Serial No. 0000-000
Valid until December 31, 2021
IBP Lifetime No. 000000/Pampanga
PTR No. 0000000/January 04, 2020/Angeles City

EXPLANATION

This certifies that personal service was not resorted to for the
reason that due to time, distance and manpower constraints, the same
is not practicable.

ATTY. RAYMOND G. RONQUILLO

Copy Furnished:

CLERK OF COURT
Municipal Trial Court
Branch IV, Angeles City

ATTY. FRANCISCO L. RAMON

Counsel for the Defendant
Room 11, 2165 Anson Tower II
Bldg., Sto. Rosario, Angeles City

OLIVER QUEEN
Defendant
19-30 Yvette St. Essel Park
Subdivision, Brgy. Telabastgan,
Angeles City, Pampanga,
Philippines

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