Republic of the Philippines

Municipal Trial Court

Branch 1
Makati City

Ms. Ivory Salazar

Case no. 1

Civil

Accompanied by his Attorney-in-fact

Unlawful Detainer
Atty. Angelique Arca
-versusMr. James Bartolo
x----------------------x
COMPLAINT

COMES NOW, the plaintiff together with the undersigned

counsel to this most honorable court, MOST RESPECTFULLY
STATES THAT;
1. The Plaintiff is of legal age, single and resident of San Antonio,
Makati City. The Defendant is likewise of legal age, married and
temporary residing at Legaspi Village, Makati City.
2. The Plaintiff is the owner of the single-storey house unit located at
Legaspi Village, Makati City, and having a residential address of XY
123 as evidence pertinent documents like tax declaration and deed
of sale.
3. The Defendant is the lessee of the house unit that is owned by the
Plaintiff as evidence of contact of lease that both parties signed.
4. The Plaintiff and the Defendant came to an agreement of lease Jan 4
2014, which they both agreed and signed as contact of lease.
5. Item No. 5 of the contract of lease which the Defendant duly signed
expressly provides that he will only be occupying the property for
one (1) year, after which, he will vacate the house when the term
expires.
6. On May 30 2015, the Plaintiff return, and discovered that the
Defendant did not vacate the property as expected.

7. The Plaintiff confronted the claim of the Defendant that the contract
signed was instead a DEED OF SALE not CONTRACT OF LEASE, and
therefore Defendant is the owner of the house unit.
8. On July 15 2015, after continuous demands, the defendant
constantly refuses to vacate the house unit and even invited
relatives to stay with him.
9. The Defendant willfully and maliciously violated the agreement
which they mutually agreed upon, and which the defendant signed.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed
of this Honorable Court the judgement be rendered in favor if the
plaintiff and that after judgement.
1. The Defendant shall vacate the house unit owned by plaintiff.
2. The Defendant shall be ordered to pay P 200,000.00 for the
Attorneys Fees.
Such other reliefs and remedies under the premises are likewise prayed
for.
Makati City, Philippines, this 19th day of July.

Attorney Angelique Arca

Counsel for Plaintiff

VERIFICATION AND CERTIFICATION

I, Ivory Salazar, of legal age, single, Filipino Citizen and a resident of San
Antonio, Makati City, after being sworn according to law, hereby depose
and state that;
1. I am the Complainant in this proceeding.
2. I have read and understood the filed complaint and allegations
therein.
Ivory Salazar
Complainant
In witness thereof, I Ms. Angelique Arca, counsel of the plaintiff, have her
unto set my hand this 19th of July Makati City.

Attorney Angelique Arca

Counsel for Plaintiff

ARCA ANGELIQUE R.
Practice Court 1 Civil
Complaint