Republic of the Philippines

Third Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
City of Malolos Bulacan
Branch 2

Bong-bong Pascual, Attorney-In-Fact for

Spouses Manny and Jinkee Pascual
Plaintiff

-versus- Civil Case No. 292 -M-2022

For: Unlawful Detainer

Spouses Robby Padilla, and Marel Padilla,

Defendant
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COMPLAINT

PLAINTIFF, through the undersigned counsel, most respectfully

states:

1. That the plaintiff is a Filipino, of legal age, single, and residing at

San Pablo, Malolos, Bulacan and the Attorney in Fact for the Spouses
Manny and Jinkee Pascual representing the latter’s interest whereas
defendant is likewise a Filipino, of legal age, married and residing at
Madera Homes, Tikay, Malolos, Bulacan

2. That on May 5, 2019 the, Spouses Manny and Jinkee Pascual with
the plaintiff being a witness, entered into a lease agreement with the
defendant on the house of Spouses Manny and Jinkee Pascual for a term of
three (3) years with a monthly rent of FIFTEEN THOUSAND PESOS (P
15,000.00) a month.

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 3. That the defendant occupies the house and lot and has been
religiously paying the monthly rentals.

4. That starting on May 5 2021 up to the present, defendant failed to

pay their monthly rents.

5. That despite several demand letters, defendant still refuses to

vacate the said house and lot.

6. That the dispute has been referred to the Baranggay but the parties
have failed to arrive at an amicable settlement.

PRAYER

WHEREFORE, it is most respectfully prayed upon this Honorable

Court that after due hearing, judgment be rendered in favor of plaintiff and
against the defendant in this manner:

1. For the payment of ONE HUNDRED EIGHTY THOUSAND PESOS

(P 180,000.00) plus an interest rate of 2% for every non-payment.

2. For the restitution of the abovementioned house and lot

3. Ordering the defendant to pay attorney’s fees in the amount of P

200,000.00 and P 5,000.00 per hearing appearance and costs of suit.

Plaintiff likewise pray for such reliefs just and equitable under the
premises.

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 VERIFICATION AND CERTIFICATION OF
NON-FORUM SHOPPING

I, Bong-bong Valdez, of legal age, Filipino, single, and a resident of

San Pablo, Malolos, Bulacan, Philippines,under oath, do hereby depose
states that:

1. I am the plaintiff in the said case

2. I have caused the preparation of the complaint and attest to the

veracity of the allegations as stated in the complaint

3. I have read and understood all the allegation and attest to the veracity
of all the documents attached in the complaint

4. I further certify that I have not commenced or filed any claim

involving the same issues herein with any other Court, Tribunal or
Quasi-Judicial Agency or I am not aware of any such other case or
claim pending before any other Court Tribunal or Quasi-Judicial
Agency.

5. Should I therefore learn of the filing or pendency of such similar

action or claim, I will inform this Honorable Court of such fact within
five (5) days from knowledge thereof.

IN WITNESS WHEREOF, WE HAVE HEREUNTO SET OUR

HANDS THIS 5th DAY OF June 2021 AT Tikay, Malolos, Bulacan

Bong-bong Valdez
Affiant

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BEFORE ME, a Notary Public, for and in the City of Malolos Bulacan this
5th day of June 2021, Personally appeared:

Bong-bong Valdez 34567890 May 5, 2019/ City of Malolos

Atty. John Dela Cruz

MAHAL, SINGH-ILL Law Office,
Unit No. 14 Cabanas, Longos, Malolos, Bulacan
PTR No. 8645920/02-10-2022/Malolos, Bulacan
IBP No. 177872002-10-2022/Bulacan
Roll of Attorney’s No. 59539
Tel No. 044-794-9874
Mobile No. 0933-820-6560
MCLE Compliance No. VI-000037, August 1, 2016
Email address: lordthankyou81773@gmail.com

Doc No.
Page No.
Book No.
Series of 2021

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