Republic of the Philippines

[COURT]
Manila

[NAME]__________, Case No. ___________
Petitioner,

- versus -

[NAME]__________,
Respondent(s).
x ----------------------------------- x

COMPLAINT FOR UNLAWFUL DETAINER

PETITIONER thru counsel, unto this Honorable Court 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 rental of _____________________ (Php_______). 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 forms of relief just and equitable under the premises are likewise prayed for.


[CITY] ___________; [DATE] _________________________.

[SIGNATURE]
[NAME OF COUNSEL] ___________
Counsel for Petitioner
[ADDRESS] ______________
IBP Lifetime No. ____________; [CITY] _____________
PTR No. _______________; [DATE], [CITY]
Roll of Attorney No. _______________________
MCLE Compliance No. ____________________


VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

I, [NAME] _____________________, of legal age, do hereby state that: I am the plaintiff
in the pleading/document entitled [PLEADING/DOCUMENT BEING VERIFIED]
___________________ and in such capacity, caused this Complaint to be prepared; I have read
its contents and affirm that they are true and correct to the best of my own personal knowledge;
I hereby certify that there is no other case commenced or pending before any court involving the
same parties and the same issue and that, should I learn of such a case, I shall notify the court
within five (5) days from my notice.

IN WITNESS WHEREOF, I have signed this instrument on [DATE]_____________.

[SIGNATURE]
[NAME] _________________


SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day of
[MONTH AND YEAR]_________________, affiant exhibiting before me his Government Issued ID
no. _______________ issued on [DATE}__________________ at [PLACE OF
ISSUANCE]_____________________.


[SIGNATURE]
[NAME]_______
Notary Public

Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________

Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.



Copy furnished through personal service:

[NAME OF COUNSEL] __________________
Counsel for the Defendant
[FIRM NAME] _______________
[ADDRESS] ________________