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CHARLOTTE F.

GALLEGO
PRACTICE COURT ASSIGNMENT NO. 2
September 18, 2014
________________________________________________________________________
___

Republic of the Philippines


Municipal Trial Court
Branch 1
Digos City

Mr. Man Resa, plaintiff


No. 10345

Civil Case
for: Unlawful

Detainer
-versusMr. Roman Sanchez, Defendant
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, married and a resident of Block 5 Lot 13

Emily Homes Subdivision, Digos City. The Defendant is likewise of legal age,
single and temporary residing at Central Planes Subdivision, Digos City.
2.

The Plaintiff is the owner of a house and lot located at Central Planes

Subdivision, Digos City.


3.

The Plaintiff allowed Roman Sanchez, defendat, to occupy the subject

property free of charge with the twin conditions: a). that instead of paying
rentals on the premises, defendant will pay the corresponding taxes on the
land; and b). that defendant will leave and vacate the premises anytime the
plaintiff so demand.
4.

Sometime in January 2013, petitioner notified defendant that he

already needs the property and that defendant must vacate immediately.

5.

The defendant refused to vacate despite repeated demands, claiming

ownership over the subject property.


6.

The defendant alleged that they already bought the property from a

certain Juan Miguel.


7.

The defendant thru his acts had therefore maliciously and unlawfully

detained the land since January 2013.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this


Honorable Court that judgment be rendered in favor of the plaintiff and that
after judgment;
a.
b.

The defendant shall vacate the house unit owned by the plaintiff.
To pay the amount of P5,000.00 per month as compensation for the
reasonable use of the subject premises until he finally vacate the said

c.

premises;
The defendant shall be ordered to pay P 120, 000 for the Attorneys

d.

Fees.
Such other reliefs and remedies under the premises are likewise
prayed for.

Digos City, Philippines, this 18th day of September 2014.

Atty. Charlotte F. Gallego


Counsel for the Plaintiff
PTR No. 1020304050:B.C.
IBP No, 1234567:B.C.
Roll No. 1234:5-10-21: Digos

VERIFICATION/CERTIFICATION OF FORUM SHOPPING


Republic of the Philippines )
City of Digos

) S.S.

I, MAN RESA, of legal age, Filipino citizen, married and resident of Block 5 Lot
13 Emily Homes Subdivision, Digos City, after having been duly sworn to in
accord Nance with law do hereby depose and say:
That I am the plaintiff in the above-entitled case;
That I have caused the preparation of the foregoing complaint and have read
the allegations contained therein;
The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
I hereby certify that I have not commenced any other action or proceeding
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
therein;
That if I should learn thereafter that a similar action or proceeding has been
filed or is pending, I hereby undertake to report that fact within five (5) days
therefrom to the court or agency where the original pleading and sworn
certification contemplated herein have been filed;
I executed this verification/certification to attest to the truth of the foregoing
facts and to comply with the provisions of Adm. Circular No. 04-94 of the
Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 24th
of September 2012, in the City of Digos.

MAN RESA

SUBSCRIBED AND SWORN to before me this _______ day of September,


2012, in the City of Digos, affiant exhibiting to me his Drivers License No.
01234 issued by the Land Transportation Office on April 8, 2012 at the City of
Manila.

Atty. Charlotte F. Gallego


Counsel for the Plaintiff
PTR No. 1020304050:B.C.
IBP No, 1234567:B.C.
Roll No. 1234:5-10-21: Digos