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LEONORA Q.

LEGASPI
1JD-C
REPUBLIC OF THE PHILIPPINES
METROPOLITAN TRIAL COURT
QUEZON CITY
Branch 123

ABC CORPORATION,
Plaintiff,
CIVIL CASE No. 000324
-versus-

FOR: Ejectment (Forcible

JUAN DELA CRUZ,

Entry)

Defendant.
x-----------------------------------x
COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most respectfully submit this Complaint for Forcible Entry and in
support hereof makes the following assertions:
1. That the plaintiff, ABC Corporation, is a private corporation with business
address at No. 25 Matalino Street Teachers Village, Quezon City, where it may
be served with summons and other judicial process of this Honorable Court;
2. That the defendant, Juan Dela Cruz, is of legal age, married to Maria B. Dela
Cruz, sole proprietor of JDC Food Enterprises with business address at Rm.
2037 Centerpoint Building, San Juan, Metro Manila, where he may be served
with summons and other Court processes;
3. That the plaintiff is the owner of QRS Condominium, located at 1230 Emerald
Avenue, Ortigas Center, Pasig City, as shown in the Condominium Certificate
of Title No. 112181 and Tax Declaration No. 00528, attached herein as Annex
A and Annex B, respectively;
4. That on July 10, 2014, defendant without the knowledge, consent and
authority of the plaintiff, through stealth and strategy occupied the
condominium unit at QRS Condominium;

5. That on July 15, 2014, plaintiff sent a letter of demand to vacate the
condominium which was received by the defendant as shown in the registry
return receipt hereto attached as Annex C;
6. That despite said letter of demand which was repeated by oral demands, the
defendant continued to occupy the condominium unit without any just or
legal reason;
7. That the act of the Defendant in unlawfully occupying the questioned
condominium unit compelled the Plaintiff to file this action and incur
damages consisting of attorneys fees in the amount of THIRTY THOUSAND
PESOS (Php30,000.00) and filing fee, cost of transportation and other
miscellaneous accommodation of its lawyers and other personal expenses to
be incurred in attending the hearings of this case in the amount of THIRTY
THOUSAND PESOS (Php30,000.00);
8. As further consequence of the defendant refusal to surrender and restore
peaceful possession of the condominium, plaintiff is entitled to recover the
monthly rental which he should have earned in the amount of FIFTEEN
THOUSAND PESOS (Php15,000.00) per month. Damages have accrued at this
rate since July 10, 2014 and will continue to accrue until defendants have
vacated the premises;
WHEREFORE, premises considered, it is most respectfully prayed unto this
Honorable Court that, after proceedings, judgment be rendered in favor of the
PLAINTIFF and ordering the defendant to:
1. Permanently vacate the premises in controversy and give the immediate right
of possession to the PLAINTIFF;;
2. Pay the amount of FIFTEEN THOUSAND PESOS (Php15,000.00) per month as
compensation for the reasonable use of the subject premises until they finally
vacate the said premises;
3. Pay plaintiff the amount of THIRTY THOUSAND PESOS (Php30,000.00) by
way of attorneys fee;
4. Pay the plaintiff the cost of the suit.
City of Manila, August 26, 2014.

ATTY LEONORA LEGASPI


Counsel for the Plaintiff
PTR No. 12345678:1-02-03: A.B.

IBP No. 123456:1-02-03: A.B.


Roll No. 12345:1-02-03:Manila
Rm. 803, Regalia Towers, P. Tuazon Ave.,
Cubao, Quezon City

VERIFICATION AND CERTIFICATE OF NON-FORUM SHOPPING


Republic of the Philippines )
City of Manila

) S.S.

I, Ronnie Santos, of legal age, under oath, respectfully state:


1. I am the Property Manager of the plaintiff, ABC Corporation;
2. Upon the instruction and authority of plaintiff, I caused the preparation
and filing of the foregoing Complaint;
3. The facts stated in the above complaint are true and correct to the best of
my knowledge and authentic records;
4. I have not commenced any action or file any claim involving the same
issues in any court, tribunal, or quasi-judicial agency and to the best of my
knowledge, no such other action or claim is pending in them; and
5. If I should learn that the same or similar action or claim has been filed or
is pending after its filing, I shall report that fact within five (5) days from
notice to the court or where the complaints or initiatory pleading has been
filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 26th day of August 2014
in Quezon City, Metro Manila.
RONNIE SANTOS
SUBSCRIBED AND SWORN to before me this 26th day of August 2014 in Quezon
City, Metro Manila, affiant exhibiting to me his Community Tax Certificate No.
12345678910 issued on August 26, 2014 at Quezon City, Metro Manila.
Doc. No. 012345;
Page No. 123;

Book No. 345;


Series of 2014

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