OMPLAINT 

Plaintiff, by counsel, respectfully alleges: 

1. That Plaintiff is married, Filipino citizen and residing at _________-- where he may be
served with court processes, motions and decisions while defendant is a Filipino citizen,
married and residing at _______ where he may be served with summons and other court
processes; 

2. That plaintiff is the owner of a land over which an apartment had been constructed,
located at ______; 

3. That by virtue of a contract of lease, plaintiff leased unto the defendant the aforesaid
apartment for a consideration so _______________ (Php__________________) a month as
rental to be paid within the first ten (10) days of each month starting______ (date); 

4. That defendant failed to pay the agreed rental for several months starting from ______ up
to present; 

5. That on ______, plaintiff sent a letter of demand to vacate the apartment which was
received by the defendant as shown in the registry return receipt hereto attached; 

6. That despite said letter of demand which was repeated by oral demands defendant failed
and still refused to pay the agreed rentals and to vacate the apartment; 

7. That by reason of the failure of the defendant to vacate the premises and to pay the
unpaid rentals, plaintiff was compelled to file this complaint engaging the services of counsel
in the amount of ______; 

WHEREFORE, it is respectfully prayed that judgment be rendered ordering the defendant 

to vacate the premises to pay the unpaid monthly rentals in the amount of ______ and
further 
rentals until the said defendant fully vacates the premises and to pay the costs of the suit. 

Plaintiff prays for such other reliefs, as the Honorable Court may deem just and equitable
under the premises.

________ City, Philippines, this _____ day of _______2011. 

Name ____________________________ 
Office Address ____________________ 
Roll of Attorney No. ________________ 
PTR No.___, ___ (date and place of issue) 
IBP No. ____, ___ (date of issue) (chapter) 

VERIFICATION with CERTIFICATION OF NON-FORUM SHOPPING