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Republic of the Philippines

National Capital Judicial Region


METROPOLITAN TRIAL COURT
Branch 16, Valenzuela City

J.P. HERMOSO REALTY, INC.,


Plaintiff,

-versus- Civil Case No. 181381-CV


FOR: Unlawful Detainer

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.
x----------------------------------------------x
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.

WHEREFORE, premises considered, it is most respectfully prayed unto


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

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.

City of Valenzuela, October 24, 2019.

NUGUIT AND MORALLOS LAW OFFICE


Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Valenzuela City

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

Republic of the Philippines )


City of Manila ) S.S.

I, JP Hermoso Realty, Inc, a domestic corporation, with the principal


business address at 123 Benitez Street, Manila, 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 24th


of October 2019, in the City of Valenzuela.

JP Hermoso Realty, Inc

SUBSCRIBED AND SWORN to before me this 24th day of October, 2019, in


the City of Valenzuela, affiant exhibiting to me his Driver’s License No. 12345
issued by the Land Transportation Office on April 8, 2012 at the City of
Manila.

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

Doc. No. ________


Page No. _______
Book No. _______
Series of 2019