Republic of the Philippines

Municipal Trial Court in Cities

8th Judicial Region
Branch 2, Tacloban City

JULIA DELA CRUZ,

Plaintiff,

-versus- Civil Case No. 12345

For: Unlawful Detainer
BEA SANTOS,
Defendant,

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel

and unto this Honorable Court, most respectfully avers:
1. That the plaintiff, JULIA DELA CRUZ, is of legal age, Filipino citizen,
single, with residence and postal address at Brgy. 99, Diit, Tacloban
City;
2. That the defendant, BEA SANTOS, is of legal age, Filipino citizen,
single, with residence and postal address at Door 5 Dela Cruz Bldg.,
Maharlika Highway Nula-Tula, Tacloban City, where they may be
served with summons and other court processes;
3. The plaintiff is the owner of a land over which an apartment had
been constructed located at Maharlika Highway, Nula-Tula,
Tacloban City;
4. By virtue of a contract of lease, the plaintiff leased unto the
defendant the aforesaid apartment for a consideration of
P12,000.00 a month as rental to be paid within the first ten (10) days
of each month starting March 10, 2018;
5. The defendant failed to pay the agreed rental for several months
starting September 10, 2018 up to the present;
6. That plaintiff sought to settle the issue through the barangay, but
defendant failed to appear on three occasions despite due notice.
7. On February 10, 2019, the plaintiff sent a final letter of demand to
pay and vacate the apartment which was received by the defendant
as shown in the registry return receipt hereto attached as Annex “A”;
8. Despite said letter of demand which was repeated by oral demands,
the defendant failed and still refused to pay the agreed amount of
rentals and to vacate the apartment;
9. By reason of failure of the defendant to vacate the premises and to pay
the unpaid rentals, the plaintiff was compelled to file this complaint
engaging the services of counsel in the amount of P15,000.00.

WHEREFORE, premises considered, it is most respectfully

prayed unto this Honorable Court that, after hearing, judgment be
rendered ordering the defendant:

1. To vacate the subject premises;

2. To pay the amount of P12,000.00 per month as compensation for the
reasonable use of the subject premises until they finally vacate the said
premises;
3. To pay the plaintiff the cost of the suit.

City of Tacloban, July 1, 2019.

By:

ATTY. DARRYL I. AÑONUEVO-CAÑETE

Notary Public
PTR No. 123456, Tacloban City 01-05-19
IBP OR No. 789101, Tacloban City 01-04-19
Roll No. 160161, May 24, 2018
MCLE VI 1262522, October 26, 2018, Pasig City

CAÑETE & CAÑETE LAW OFFICE

2nd Floor Uytingko Bldg.
Del Pilar St. Tacloban City
 VERIFICATION/CERTIFICATION AGAINST NON-FORUM
SHOPPING

Republic of the Philippines )

City of Tacloban ) S.S.

I, JULIA DELA CRUZ, of legal age, Filipino citizen, single and

resident of Brgy. 99, Diit, Tacloban City, after having been duly sworn
to in accordance with law do hereby depose and say:

1. That I am the plaintiff in the above-entitled case;

2. That I have caused the preparation of the foregoing complaint and
have read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
4. 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;
5. 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;
6. 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 1st of July 2019, in the City of Tacloban.

JULIA DELA CRUZ

 SUBSCRIBED AND SWORN to before me this 1st day of July,
2019, in the City of Tacloban, affiant exhibiting to me her Driver’s
License No. 12345 issued by the Land Transportation Office on April
5,2016.

ATTY. DARRYL I. AÑONUEVO-CAÑETE

Notary Public
nd
2 Floor Uytingko Bldg.
Del Pilar St. Tacloban City
PTR No. 123456, Tacloban City 01-05-19
IBP OR No. 789101, Tacloban City 01-04-19
Roll No. 160161, May 24, 2018
MCLE VI 1262522, October 26, 2018

CAÑETE & CAÑETE LAW OFFICE

2nd Floor Uytingko Bldg.
Del Pilar St. Tacloban City

Doc. No. 25
Page No. 08
Book No. 15
Series of 2019.