REPUBLIC OF THE PHILIPPINES

11th JUDICIAL REGION

Municipal Circuit Trial Court in Cities
Digos City, Davao del Sur

URIEL PIETER PABALAN,

Plaintiff,
-versus-

CIVIL CASE No. _____________

FOR: Unlawful Detainer

ELLEN G. ADARNA,
Defendant.
x-----------------------------------x

COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable
Court, most respectfully avers:
1.

That the plaintiff, URIEL PIETER PABALAN, is of legal age, Filipino citizen, single,
with residence and postal address at 2269, Lim Ext., Digos City
;
2.
That the defendant, ELLEN G. ADARNA, is of legal age, Filipino citizen, single, with
residence and postal address at 926, IMD Bldg., Lim Ext., Digos City, where they may be served
with summons and other court processes;
3.

The plaintiff is the owner of a land over which a residential house had been constructed
located 926, IMD Bldg., Lim Ext., Digos City;

4.

By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid
apartment for a consideration of P5,000.00 a month as rental to be paid within the first ten (10)
days of each month starting November 3, 2011;

5.

The defendant failed to pay the agreed rental for several months starting February 19,
2014 up to the present;

6.

On May 3, 2014, the 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 as Annex A;

7.

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 vacated the apartment;

8.

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.
2.

3.

To vacate the subject premises;

To pay the amount of P5,000.00 per month as compensation for the reasonable use of the
subject premises until they finally vacate the said premises;
To pay the plaintiff the cost of the suit.

City of Manila, September 24, 2012.

ADVINCULA-RODRIGUEZ LAW OFFICE
Counsel for the Plaintiff
Door 22, RMR Building
Lim Extension, Digos City
By:
RAMON MIGUEL E. RODRIGUEZ
Roll of Attorney No. 8715037231412312
IBP No. 12312312445/2-5-12/Digos
PTR No. 87612412354/12-22-11/Digos

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

I, URIEL PIETER PABALAN, of legal age, Filipino, single and a resident of Lim
Extension, Digos City, Davao del Sur, Philippines, after having been duly sworn to in accordance
with law, do hereby depose and say:
1. That I am the Plaintiff in the above case;
2. That I have caused the preparation of the above complaint.
3. That I have read and understood all the contents thereof;
3. That the same are true and correct to the best of my personal knowledge and based on
authentic records;
4. That I have not commenced or filed any action or proceeding involving the same
issues as in this case at bench in any branches of this Court, or any other courts and
other tribunal or agency whatsoever and to the best of my knowledge, no such action
or proceeding is instituted nor have been pending in the Supreme Court, Court of
Appeals or other different divisions thereof, or any other tribunal or agency thereof;
5. That if I would thereafter learned that similar action or proceeding has been pending
before the Supreme Court or any other courts or tribunal thereof, then I will inform
this court within five days from the knowledge of the same.
In witness hereof, I have hereunto set my hands this __________________ at Digos City,
Philippines.
RURAL BANK OF DIGOS INC.,
Represented By:
URIEL PIETER PABALAN
Affiant

SUBSCRIBED AND SWORN TO before me this ___________________at Digos City,

Davao del Sur, Philippines, affiant exhibiting to me his valid identification No. as above
indicated.