REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL REGION
PASIG CITY

MENDOZA TAFALLA
KATIGBAK & UMBALIN
LAW OFFICE ("MTKU LAW)

-versus- Civil Case No._____________________

For: Specific Performance
EAGLE ENTERPRISES, INC. (EEI)

x-------------------------------------------x

COMPLAINT

Mendoza Tafalla Katigbak & Umbalin Law Office ("MTKU) through

undersigned counsel respectfully states that:

1.1 Mendoza Tafalla Katigbak & Umbalin Law Office (MTKU Law)

is a corporation duly organized and existing under the laws of

the Philippines with address at 24 th floor Joy Nostalg Center,

17 ADB Avenue, Ortigas Center, Pasig City may be served with

pleadings, orders and other court processes through

undersigned counsel at the address provided below.

1.2 Eagle Enterprises Inc. (EEI) is a corporation duly organized

and existing under the laws of the Philippines with address at 7

Stella Maris Pasig City where they may be served with orders

and processes of this Honorable Court.

1.3 Attys. Mark Mendoza, Raquel Tafalla, Regalado Katigbak, and

Raquel Umbalin all graduated from the same prestigious law

school. They all passed the Philippine Bar Exam with ease

13years ago.
1.4 All were employed in a law firm in Makati when they finally

decided to put up their own law office with the purpose of

exploring new opportunities and for greener pastures.

1.5 In order for them to achieve their goal, they needed to find a

suitable place to entertain their clients. After scouting for an

office space they finally found 24 th floor Joy Nostalg Center, 17

ADB Avenue, Ortigas Center, Pasig City, which was owned and

controlled by EEI through Jay S. Arcilla.

1.6 MTKU immediately sent Letter of Intent manifesting their desire

to lease the unit. EEI after receiving the Letter of Intent, agreed

to lease the unit to MTKU.

1.7 EEI and MTKU drafted a Lease Contract which include an

Option to Renew, stated as follows:

4. OPTION TO RENEW: This lease may be

renewed at the option of the LESSEE, subject

to the latters written notice of intention to

renew the lease which shall be served to the

LESSOR not later than sixty (30) days prior to

the expiry date of the period herein agreed

upon;
1.8 EEI agreed with all the terms and conditions of the

Lease Contract and signed said agreement with no

 reservations. MTKU then started their operations in

said unit.
1.9 MTKU Laws practice flourished and after two years

when they realized that the lease contract was about to

expire, they decided to exercise their power to renew

the lease contract. Thirty (30) days prior the expiration

of said Lease Contract, MTKU sent a letter to EEI

manifesting its intention to renew the lease contract.

1.10The Letter of Intent clearly stated MTKUs intention to

renew the lease as stated below:

Dear Sir,
On behalf of MTKU Law Office, I
would like to express our interest to renew
our lease contract on your subject property
located at 24th floor Joy Nostalg Centre, 17
ADB Ave., Ortigas Center, Pasig City. For
the past two years of our stay our law firm
has been doing good and it would be
disadvantageous on our part if we will
change our office address. Moreover our
clients have been used to.
Attached herewith
is our proposed renewal of the lease
contract. Please feel free to contact us on
the aforementioned contact details of our
office.

We are very much eager to

continue doing business with you.

xx x

1.11EEI after the receipt of the Letter of Intent, deniedthe same and
instead offered to sell the said unit for the Five Million Four
Hundred thousand pesos (P5.4 Million) which was above the
market value.
 1.12 MTKU explained to EEI that it was still not in a position to
acquire said property but EEI through Mr. Arcilla still did not
allow the renewal of said contract of lease.

1.13MTKU was then asked to vacate the Unit since the lease
contract is about to expire, otherwise EEI will be constrained to
evict the MTKU Law from the Unit.

1.14MTKU then formally challenge EEI to honor said contract

agreement through a demand letter dated October 9, 2018,
which stated:

We are writing to you to express our intent to

exercise our right to renew the above mentioned
Contract of Lease at the 26th floor, Joy Nostalg
Centre, 17 ADB Avenue, Ortigas Center, Pasig City.

The MTKU Law Office has already expressed to

you its intent to renew the said Lease of Contract
earlier but you have refused to honor the Option to
Renew Clause written under our Contract of
Lease. May we remind you that failing to honor the
said Clause would result to a Breach of Contract.

Accordingly, DEMAND is hereby made upon you to

honor the Option to Renew Clause on or before
the expiry of our Contract of Lease, November 9,
2018.

We trust that you will give this matter your prompt

and preferential attention to avoid the expense and
inconvenience of litigation.

1.15 A month passed and still EEI has not yet responded
to the Demand Letter and the lease contract is about
to expire. This is why MTKU in order to protect their
rights have decided to find relief in this Honorable
Court.

PRAYER

In view of the foregoing, the plaintiffs respectfully prays the

Honorable Court to render judgment:

1. Ordering EEI to honor the Lease Contract Agreement

 2. Ordering EEI to allow the exercise of the power to renew

the Lease Contract Agreement.

Other reliefs just and equitable under the premises prayed for.

Pasig City,