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COMPLAINT FOR UNLAWFUL DETAINER

(Caption and Title)

COMPLAINT

Plaintiff, thru counsel, respectfully avers that:

1. The plaintiff is of age and a resident of__________________ while the defendant


is also of age, with residence at_____________, where he may be served with summons and
other court processes;

2. The plaintiff is the absolute owner and lessor of a certain building located
at__________________, currently being leased and occupied by the defendant;

3. The defendant leases and occupies the said building under the express obligation
of paying a monthly rent of ___________________ (₱____). Payable within the first five (5)
days of each month;

4. The defendant has failed to pay the rents for the months of_______________,
which now amounts to___________________;

5. Without any legal justification, defendant continuously refuses to pay the said
amount despite repeated oral and written demands. A final demand letter was sent and received
personally by defendant on__________, or more than five (5) days before the filing of this
complaint. A copy of the final demand letter to pay the arrears and to vacate the premises is here
attached as Annex “A.”

WHEREFORE, it is respectfully prayed that after due hearing, judgment be rendered in


favor of the plaintiff:

a. For the restitution of the abovementioned premises; and

b. For the payment of_______________, representing the arrears of rent now


overdue, with legal interest from the filing of this complaint, and costs of suit.

Other reliefs just and equitable are likewise prayed for.

(Venue, date, signature)

(VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING)

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