Republic of the Philippines

Municipal Trial Court

Fifth Judicial Region
Daraga, Albay

Civil Case No. 1488

For: Unlawful Detainer
MR. A,
Plaintiff

versus

MR. B,
Defendant
x------------------------x
COMPLAINT
Plaintiff, by counsel, most respectfully states:
1. The plaintiff is of legal age, with the capacity to sue a d be sued, a resident of
Illawod, Daraga, Albay, while the defendant is likewise of legal age, with capacity
to sue and be sued, and a resident of Illawod, Daraga Albay.

2. Plaintiff is the absolute owner of the residential house located in Illawod, Daraga,
Albay covered by CTC No. T-55647. Copy of CTC No. T-55647 hereto attached
as Annex A.

3. By virtue of a contract of lease, the plaintiff leased unto the defendant the
aforesaid Residential House for a consideration of P5,000.00 a month as rental
to be paid within 1 year. Copy of the contract is hereto attached as Annex B.

4. The defendant failed to pay the agreed rental on the 6 th month up to the
present.

5. The plaintiff through his counsel sent a letter of demand to vacate the apartment
which was received by the defendant as shown in the registry return receipt
hereto attached as Annex “C”.
 6. Despite said letter of demand, the defendant failed and still refused to pay the
agreed amount of rentals and to vacated the apartment.

7. 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 P10,000.00.

8. The aforesaid act of the defendant is clearly a violation of plaintiff’s right

respecting the subject matter of action;

  WHEREFORE, premises considered, it is most respectfully prayed unto this

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

1. To vacate the subject premises;

2. To pay the amount of P5,000.00 per month as compensation for the reasonable
use of the subject premises until they finally vacate the said premises;
3. To pay the plaintiff the cost of the suit.

Plaintiff’s further pray for other relief’s just and equitable under premises.

Legazpi City, March 29, 2021.

BASILONIA & BASILONIA LAW OFFICE

Counsel for the Plaintiff
Rom. 4, 2nd Floor, PYC Building
Old Albay, Legazpi City

By:

CHARINA B. BASILONIA(SGD)
IBP NO. PAID-01-04-20
PTR NO. 4567286-01-04-20
ROLL NO. 34256
MCLE COMP. NO. VI-0896758
Valid From: 01-02-20 to 04-14-22
 VERIFICATION AND CERTIFICATE

I, Mr. A, of legal age, Filipino citizen and a resident of Illawod, Daraga, Albay,
under oath depose and say:

1. That I am the plaintiff of the above title case;

2. That I have caused the preparation and filing of this case;

3. That I affirm the allegations contained therein are true and correct based of my
own personal knowledge and authentic records;

4. That there is no other case involving the same parties and issues, filed and
pending before the Supreme Court, Court of Appeals and or any other tribunal or
agency;

5. That if I should thereafter learn that there is a similar action or proceedings that
has been filed or pending before the Supreme Court, Court of Appeals or any
other tribunal or agency, I undertake to report this fact within five (5) days to this
Honorable Court.
6. I executed this verification/ certification to attest the truth for the foregoing facts
and to comply with the provision of Admin Circular No. 04-94 of the Honorable
Supreme Court.

IN WITNESS WHEREFOR, I have affixed my signature this 29 th of March, 2021, in

the municipality of Daraga.

MR. A(SGD)

Subscribe and Sworn to before me in the City of Legazpi, this 29 th day of March,
2021by MR. A, personally known to me that she is the same person who personally
signed the foregoing complaint before me and acknowledge that she executed the
same in my presence.

CHARINA B. BASILONIA(SGD)
IBP NO. PAID-01-04-20
PTR NO. 4567286-01-04-20
ROLL NO. 34256
 MCLE COMP. NO. VI-0896758
Valid From: 01-02-20 to 04-14-22

Doc. No. 347

Page No. 449
Book No. 123
Series of 2021