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REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT


San Jose Del Monte City
Branch 1

ARLYN D. MACALOOD,
              Plaintiff,
                                                                 CIVIL CASE No. 800921
                         -versus-                           FOR: Unlawful Detainer
With Damages
JAMES REID,
                Defendant.

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

COMPLAINT

COMES NOW, the plaintiff, through the undersigned


counsel and unto this Honorable Court, most respectfully avers:

1. That the plaintiff, ARLYN D. MACALOOD, is of


legal age, Filipino citizen, single, with residence and
postal address at B3 L4 Green Leaf Classic 2, San Jose
Del Monte, Bulacan;

2. That the defendant, JAMES REID, is of legal age,


Filipino citizen, single, with residence and postal
address at No. 56 Regalado, Fairview, Quezon City,
where they may be served with summons and other
court processes;

3. The plaintiff is the owner of a land over which a


small warehouse had been constructed located #28
COMPLAINT
Civil Case No. 800921
Macalood vs. Reid
Page 2 of 6

Paradise Farm, Tungkong Mangga, San Jose Del


Monte, Bulacan.

4. By virtue of a contract of lease, the plaintiff leased


unto the defendant the aforesaid warehouse for a
consideration of P12,000.00 a month as rental;

5. The defendant failed to pay the agreed rental for


several months starting March 2019 up to the
present;

6. On June 10 and July 10, 2019 the plaintiff sent a


letter of demand to vacate the apartment which was
received by the defendant as shown in the receiving
copy hereto attached as Annex “A”;

7. Despite said letters of demand which was repeated


by oral demands, the defendant failed and still
refused to pay the agreed amount of rentals and to
vacated the apartment;

8. 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 P10,000.00.
COMPLAINT
Civil Case No. 800921
Macalood vs. Reid
Page 3 of 6

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 San Jose Del Monte, August 12, 20129

            RAFAELITO H. IMPERIAL


Counsel for the Plaintiff
               

Doc. No. _____;


Page No. _____; FERGUS HERNANDEZ
Book No._____; #60 Pangasinan St., Proj. 8, Q.C.
SERIES of 2019. Contact no. 8359-0211
Roll of Attorney No. 65432
IBP No. 02389/01/10/19
MCLE No. VI-0011223
P.T.R. No. A-12345678-2/1-6-2010
Q.C.

VERIFICATION/CERTIFICATION OF
COMPLAINT
Civil Case No. 800921
Macalood vs. Reid
Page 4 of 6

NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES )


SAN JOSE DEL MONTE CITY ) S. S.

I, ARLYN D. MACALOOD, of legal age, single, Filipino, and


with residence address B4, L3, Green Leaf Classic 2, San Jose Del
Monte City, Bulacan, 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 and


have caused the preparation of the foregoing complaint
and have read the allegations contained therein;
2. That I read and understood its contents which are true
and correct of my own personal knowledge and/or based
on authentic records;
3. That I have not commenced any action of proceeding
involving the same issue in the Supreme Court, the
Court of Appeals or any other tribunal or agency;
4. That to the best of my knowledge, no such action or
proceeding is pending in the Supreme Court, the Court
of Appeals or any tribunal or agency, and that, if I
should learn thereafter that a similar action or
proceeding has been filed or is pending before these
courts of tribunal or agency, I undertake to report that
the fact to the Court within five (5) days therefrom to the
COMPLAINT
Civil Case No. 800921
Macalood vs. Reid
Page 5 of 6

court or agency wherein the original pleading and sworn


certification contemplated herein been filed:
5. 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 set my hand this 12th


day of August 2019 in San Jose Del Monte City.

ARLYN D. MACALOOD
Affiant

SUBSCRIBED AND SWORN to before me this 12th day of


August 2019 in San Jose Del Monte, Philippines, affiant exhibiting to
me her GSIS ID No. 003-3406-1834-0 which was issued by the GSIS as
evidence of identity.

Doc. No. _____;


Page No. _____; FERGUS HERNANDEZ
Book No._____; #60 Pangasinan St., Proj. 8, Q.C.
SERIES of 2019. Contact no. 8359-0211
Roll of Attorney No. 65432
IBP No. 02389/01/10/19
MCLE No. VI-0011223
COMPLAINT
Civil Case No. 800921
Macalood vs. Reid
Page 6 of 6

P.T.R. No. A-12345678-2/1-6-2010


Q.C.

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