Republic of the Philippines

First Judicial Region

5TH MCTC TUBA-SABLAN
Tuba, Benguet

CLARITA CARANTES

Plaintiff.

-versus- CIVIL CASE NO. 12345

For: Unlawful Detainer

MARIA SAL-ONGAN

Defendant.
x x

COMPLAINT

The plaintiff, through the undersigned counsel and to this Honorable

Court, respectfully avers:

1. That plaintiff, Clarita Carantes, is of legal age, Filipino citizen, single,

with residence and postal address at Poblacion, Tuba , Benguet;

2. That defendant is Maria Sal-ongan, of legal age, Filipino citizen, single,

with residence and postal address at Poblacion, Tuba, Benguet, where
she may be served with summons and other Court processes;

3. The plaintiff is the owner of a land over which a house had been
constructed located at 123 Poblacion, Tuba, Benguet;

4. By virtue of a contract of lease, the plaintiff leased unto the defendant the
aforesaid house for a consideration of P15,000.00 a month as rental to be
paid within the first ten (10) days of each month starting September 3,
2021;

5. The defendant failed to pay the agreed rental for several months starting
January 19, 2022 up to the present;

6. On April 3, 2022, the plaintiff through her counsel sent a letter of demand
to vacate the house which was received by the defendant. A copy of said
demand letter is hereto attached as Annex “A”;

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 7. Despite said letter of demand which was repeated by oral demands, the
defendant failed and still refused to pay the agreed amount of rentals and
to vacate the house;

8. 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 P20, 000.00.

WHEREFORE, premises considered, it is most respectfully prayed unto

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

a. To vacate the subject premises;

b. To pay the amount of P15,000.00 per month as compensation for the

reasonable use of the subject premises until they finally vacate the said
premises;

c. To pay the plaintiff the cost of the suit.

Tuba, Benguet, April 26, 2022.

JEVAN B. DICTAAN
Counsel for the Plaintiff.
ABC Building
Poblacion, Tuba

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 VERIFICATION AND CERTIFICATION
OF NON-FORUM SHOPPING

Republic of the Philippines)

City of Manila) S.S.

I, CLARITA CARANTES, of legal age, Filipino citizen, single and

resident of Poblacion, Tuba, Benguet, after having been duly sworn to in
accordance with law do hereby depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and have
read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or
proceeding involving the same issues in any court, tribunal or quasi-
judicial agency and, to the best of my knowledge, no such other action or
claim is pending therein;
5. That if I should learn thereafter that a similar action or proceeding has
been filed or is pending, I hereby undertake to report that fact within five
(5) days therefrom to the court or agency where the original pleading and
sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular No.
04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 26th of

April 2022, in the Municipality of Tuba.

CLARITA CARANTES

SUBSCRIBED AND SWORN to before me this 26 th day of April,

2022, in the City of Iloilo, affiant exhibiting to me his TIN 1234-1234-12 issued
on 20th day of March 2021 at Tuba, Benguet.

ATTY. FAUSTO Y. MATEO JR

Notary Public
Until December 31, 2022
PTR No. 1234567
IBP No. 58637
Roll No. 123456
MCLE Compliance No. 000123

Doc. No. 1234

Page No. 2
Book No. 5
Series of 2022.
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 ANNEX “A”

April 3, 2022

Maria Sal-ongan
123 Poblacion, Tuba, Benguet

Re: Demand to Vacate

-------------------------

Dear Ms. Maria Sal-ongan:

We are writing in behalf of our client, Ms. Clarita Carantes, who referred to us for
appropriate legal action the above-captioned matter.

Facts revealed to us by our client shows that she is the lawful owner of a titled
parcel of land in his name with a house built therein which is located at 123
Poblacion, Tuba, Benguet.

Our client has been pleading you to vacate her property since she is now going to
use and lease the same. It has to be remembered that you rented the said house
before and that you stopped paying rent and despite countless oral demand you
continue to refuse to do so.

In view of the foregoing circumstances, we make this DEMAND upon you to

vacate the said premises within FIVE (5) DAYS from notice hereof. If you fail to
heed this demand, we shall be constrained to institute appropriate CRIMINAL
and CIVIL actions against you to protect our client’s interest.

We trust that you will give this matter your preferential attention.

Very truly yours,

ATTY. JEVAN B. DICTAAN

PTR No. 12324567
IBP No. 12345