FORM NO.

103
For ejectment: Contract of lease had expired; but occupant refused to vacate the
premises despite demands; with unpaid rentals. Property is located in Manila.

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
METROPOLITAN TRIAL COURT
MANILA, BRANCH _____

_____________________,
Plaintiff,
— versus — CIVIL CASE NO.________________
For: Unlawful Revolution
________________________,
Defendant.
x __________________x

COMPLAINT
PLAINTIFF, by counsel, to this Honorable Court, respectfully states, that:
1. Plaintiff is of legal age, single/married, and a resident of
___________, Manila;
2. Defendant is likewise of legal age, single, and a resident of
____________, where he may be served with summons and other processes of
this Honorable Court;
3. Plaintiff is the owner of a residential house and lot located
at___________, Manila, which was leased to the defendant for a period of five
(5) years from _______ at a monthly rental of P_______; a photocopy of the
Contract of Lease dated ________ is attached as Annex
4. The said contract of lease had already expired on ________; and was
not renewed.
Despite the expiration of the said contract of lease, the defendant failed and
refused and continuously fails and refuses to surrender and vacate the said
property and demands made by the plaintiff. A photocopy of the demand letter
dated _____________, the registry receipt, return card, private courier's receipt
and tracking history are attached as Annexes _____________, respectively; and
the signature of the recipient appearing at the upper left portion of the letter is
marked as Annex ________. The Affidavit of Service is attached
as___________.
6. Due to defendant's adamant refusal to vacate the leased premises,
plaintiff was constrained to engage the services of the undersigned counsel to
protect his interest for an agreed attorney's fees of Php_____________and
P___________ as appearance fee for every court hearing; and incur litigation
expenses of P_________.
7. The matter was referred to the Lupong Tagapamayapa of
Barangay__________, Manila; but no settlement was arrived at, as evidenced by
the Certification to File Action issued by the Barangay Chairman, which is
attached as Annex "D".
WHEREFORE, it is respectfully prayed of this Honorable Court that judgment be
rendered in favor of the plaintiff and against the defendant, as follows:
1. Ordering the defendant, and all persons claiming rights under him, to
vacate the leased premises and surrender possession thereof to the plaintiff,

2. Ordering the defendant to pay plaintiff P ______________as and for

attorney's fees and appearance fee for every court hearing; and costs of suit.
Plaintiff prays for such other reliefs as may be just and equitable under the
premises
Quezon City, ____________2020.
Counsel for the Plaintiff

VERIFICATION AND CERTIFICATION

AGAINST FORUM SHOPPING

JURAT

(Signature and Seal of the Notary Public)

(FORM NO. 1)