REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT IN CITIES

City of Mandaue
Branch ____

GAIZKA ALESSANDRO A. BONTILAO,

Plaintiff,
CIVIL CASE No. _____
-versus- FOR: Unlawful Detainer

ALYANA GENIELLE B. ACAYLAR,

Defendant.

x-----------------------------------x

COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and
unto this Honorable Court, respectfully alleges:
1. That the plaintiff, GAIZKA ALESSANDRO A. BONTILAO, is of
legal age, Filipino citizen, single, with residence and postal address at
805 Ibabao-Estancia, Mandaue City;
2. That the defendant, ALYANA GENIELLE B. ACAYLAR, is of legal
age, Filipino citizen, single, with residence and postal address at 123
Sparrow Street, Sto. Nino Village, Banilad, Cebu City, where she may be
served with summons and other court processes;
3. That the plaintiff is the owner of a land over which a house has
been constructed, located 123 Sparrow Street, Sto. Nino Village, Banilad,
Cebu City;
4. That 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 June 1, 2016;
5. That said lease contract is evidenced by a written contract of
lease signed by the plaintiff and defendant, a copy of which is hereto
attached as Annex “A” and made an integral part of this complaint.

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 6. That the defendant failed to pay the agreed rental for several
months starting September 2016 up to the present, in breach of the
contract of lease;
7. That on November 12, 2016, the plaintiff sent a letter of
demand to vacate which was received by the defendant as shown in the
registry return receipt hereto attached as Annex “B”;
8. 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;
9. 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.
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 P15,000.00 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.
Cebu City, January 20, 2017.

ATTY. JEBB LYNUS Q. CANE

Counsel for the Plaintiff
Roll of Attorneys No. 10068
IBP No. 15908 / Lifetime / Cebu City
PTR No. 456537 / January 2, 2017 / Cebu City
MCLE Compliance No. V – 089837; June 5, 2016 / Cebu City
Valderama Compound, Bugnay 1, Labangon, Cebu City

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines)

Province of Cebu ) S.S.
City of Cebu )

I, GAIZKA ALESSANDRO A. BONTILAO, of legal age, Filipino citizen,

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single and resident of 805 Ibabao-Estancia, Mandaue City, after having
been duly sworn to in accordance with law do hereby depose and state:
1. That I am the plaintiff in the above-entitled case. That I have
caused the preparation of the foregoing complaint and have read the
allegations contained therein and that the allegations in the said
complaint are true and correct of my own knowledge and authentic
records;
3. That 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. 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.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 20th day of January 2017, in the City of Cebu.

GAIZKA ALESSANDRO A. BONTILAO

Affiant/ Plaintiff

SUBSCRIBED AND SWORN to before me this 20th day of January,

2017, in the City of Cebu, affiant exhibiting to me his Driver’s License No.
498372 issued by the Land Transportation Office on December 10, 2016
at the City of Mandaue.

ATTY. JEBB LYNUS Q. CANE

Notary Public within and for the territorial jurisdiction of
RTC of Cebu City, San Fernando and Carcar City
Notarial Commission No. 8279
Until December 31, 2017
Roll of Attorneys No. 10068
IBP No. 15908 / Lifetime / Cebu City
PTR No. 456537 / January 2, 2017 / Cebu City
MCLE Compliance No. V – 089837; June 5, 2016 / Cebu City
Valderama Compound, Bugnay 1, Labangon, Cebu City
Doc. No. 5;
Page No. 1;
Book No. 8;
Series of 2017