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Republic of the Philippines

MUNICIPAL TRIAL COURT OF SIBULAN


Province of Negros Oriental

___________________________,
Plaintiff,
Civil Case No. ___________
- versus -
(For: Ejectment)
___________________________,
Defendant,
x--------------------------------------x

COMPLAINT

COMES NOW the plaintiff, by the undersigned counsel, and unto this Honorable
Court, respectfully alleges:

1. That the plaintiff is of legal age and presently residing at


_________________________, while the defendant is also of legal age and residing at
__________________________;

2. That the plaintiff is the absolute owner and lessor of that certain residential
house located at ______________, and now leased and occupied by the defendant;

3. That the defendant leases and occupies the said residential house under the
express obligation of paying a rent of Php _______ a month, payable in advance within
the first five (5) days of every month;

4. That the defendant has not paid the rents for the said residential house for the
months of ________ and __________ of the current year;

5. That furthermore, the defendant has failed to comply with the conditions of
his lease, namely, __________________________;

6. That the plaintiff has several times demanded of the demanded to vacate the
above premises and to pay his back rentals, now amounting to Php ________, the last
demand having been made on him personally and in writing on ________ or more than
five (5) days before the filing of this complaint.

WHEREFORE, it is respectfully prayed that, after due hearing, judgment be


rendered in favor of the plaintiff:

(a) For the restitution of the above mentioned premises;

(b) For the payment of ___________________________ Pesos (Php ________),


representing the arrears of rent now overdue, with legal interest from the filing of the
complaint, and costs of this suit;
(c) For attorney's fees in the amount of ___________________________ Pesos
(Php ________).

Municipality of Sibulan, Negros Oriental Philippines, this ____ day of _________,


20___.

___________________
Counsel for the Plaintiff
_____Address_______________
_____IBP No._______________
_____Roll No._______________
_____MCLE Compliance No.___

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and for


_________(City/Province)____________ this ____th day of ____________ 20___.
Affiant personally came and appeared with _____________(Competent Evidence of
Identity)______ issued by the _________(Government Agency)______ on ___(date)__
at ________(place)_________, bearing his photograph and signature, known to me as
the same person who personally signed the foregoing instrument before me and avowed
under penalty of law to the whole truth of the contents of said instrument.

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