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ERNESTO BERNARDINO
SPS. ROBERTO and ROWENA BORREROS
SPS. CASIMIRO and CONCHITA BRAVO
MELBA CUNANAN
SPS. ENREQUE and LINA MANEJA
SPS. ARTURO and JERSAM MARQUEZ
BOYET RAMOS
JOSELITO RAMOS
SPS. VICTOR and EVANGELINE RONQUILLO
SPS. EDWIN SOL and MIRASOL MARQUEZ
CHERRY LYNNE SY and
SPS. ALBERT and EVANGELINE TUAZON,
Defendants.
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COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto
this Honorable Court, most respectfully avers:
1. That the plaintiff, J.P. Hermoso Realty Inc., a domestic corporation, with
the principal business address at 123 Benitez Street, Manila;
2. That the defendants, ERNESTO BERNARDINO, SPS. ROBERTO
AND ROWENA BORREROS, SPS. CASIMIRO AND
CONCHITA BRAVO, MELBA CUNANAN, SPS. ENREQUE
AND LINA MANEJA, SPS. ARTURO AND JERSAM
MARQUEZ, BOYET RAMOS, SPS. VICTOR AND
EVANGELINE RONQUILLO, SPS. EDWIN SOL AND
MIRASOL MARQUEZ, CHERRY LYNNE SY, and SPS.
ALBERT AND EVANGELINE TUAZON, all of legal age, Filipino
citizens with residence and postal address at I. Fernando Street,
Malanday, Valenzuela City, where they may be served with summons and
other court processes;
3. The plaintiff is the owner of a land with an area of 2, 075 square meters
located at I. Fernando Street, Malanday, Valenzuela City covered by TCT
No. V-3476, Valenzuela Registry of Deeds over which the defendant
occupies;
4. That through the tolerance of the plaintiff (or its predecessor-in-interest as
amplified in the position paper) defendants occupied the subject property
with the commitment to vacate the same upon demand;
5. That there is no contract of lease between parties;
6. That sometime in the early of 2007, plaintiff informed verbally the
defendants must vacate the same;
7. That defendants refused to vacate the subject premises, thus, the plaintiff
was constrained to engage the services of a lawyer for purposes of
effecting the removal of the defendants;
8. That plaintiff through counsel sent a formal letter, dated September 17,
2007, demanding the defendants to vacate the subject premises and to pay
reasonable compensation, return receipt hereto attached as Annex “A”;
9. That despite due receipt of the said demand letter on September 28, 2007
by the defendants, the latter ignored such letter and they are still
occupying the subject property up to date. Hence, the filing of this
complaint.
1. Ordering the defendants and all persons claiming rights from them over
the subject property and to vacate the same and surrender possession
thereof to the plaintiff immediately;
2. To pay plaintiff the sum of P25, 000.00 per month for each defendant as
reasonable compensation for the continued use and occupation of the
subject premises, from September 2007 until fully vacated;
3. To pay the plaintiff jointly and severally the amount of P150,000.00 as
and by way of attorney’s fees and other expenses equitable under the
premises.
By:
JEODINARD P. NUGUIT
Roll of Attorney No. 98765
IBP No. 12345/2-5-19/ Valenzuela City
PTR No. 87654/12-22-19/ Valenzuela City
VERIFICATION/CERTIFICATION OF FORUM SHOPPING
ATTY. NO CASE
Notary Public
My Commission Expires Dec. 31, 2012
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila