Republic of the Philippines

MUNICIPAL TRIAL COURT

Cebu City

REY MALVIN PALLOMINA

                                  Plaintiff,
Civil Case No. 12345
For: Unlawful Detainer
MARIFEL ALATRACA
                          Respondent.

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COMPLAINT
PLAINTIFF, through the undersigned counsel, and unto this Honorable
Court, most respectfully avers: THAT
1. Plaintiff is of legal age, Filipino, with residence and postal address at F. Ramos
Street, Cebu City, Cebu where he may be served notices and other court processes;
2. Respondent is of legal age, Filipino, with residence and postal address at A.S.
Fortuna Street, Mandaue City, Cebu;
3. Plaintiff is the absolute owner and lessor of that certain apartment situated in
Barangay Cogon Central Ramos, Cebu City and now leased ad occupied by the
respondent;
4. Pursuant to the lease contract (Exhibit A) executed by the plaintiff and the
respondent dated December 18, 2020, the respondent is obliged to pay a monthly
rental payment of P10,000.00 to the plaintiff;

5. Respondent failed to pay the agreed rental for several months starting from April 6,
2020 up to the present.

6. A stipulation in the said lease contract provides that in case the respondent fail to
pay related to the lease of the leased property for the period of two (2) consecutive
months, the petitioner has the right to terminate the said contract and eject the
respondent.
7. On May 5, 2020, the plaintiff sent a letter of demand to vacate the apartment which
was received by the respondent as shown in the registry return receipt (Exhibit B).
8. Despite said letter of demand which was repeated after with several oral demands
to vacate the apartment, the respondent still refuses to pay the agreed amount of
rental, and failed to vacate the apartment which makes her occupation unlawful.

9. By reason of failure 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.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that after due notice and hearing, judgment be rendered in favor
of Plaintiff:
1.     For the restitution of the abovementioned apartment;
2.     For the payment of TWENTY THOUSAND PESOS (P20,000.00), Philippine
currency, representing the arrears of rent now overdue;
3.     To pay the cost of the suit
Other reliefs just and equitable under the premises are likewise prayed for.
Cavite City, Philippines, May 20, 2020.

(YOUR NAME HERE)

Counsel for Plaintiff

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines
(City of Cebu ) S.S.
 I, REY MALVIN PALLOMINA, of legal age, after having been duly sworn
in accordance with law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are true and correct
of my personal knowledge and/or based on copies of documents and records in my
possession;
4. I have not commenced any other action or proceeding involving the same issues
in the Supreme Court, the Court of Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or proceeding is pending
in the Supreme Court, the Court of Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to this
Honorable Court.

Cebu City, Philippines, May 20, 2021

__________________
Rey Malvin Pallomina

                 SUBSCRIBED AND SWORN to before me this 21st day of May 2021 at

Cebu City, Philippines affiant exhibiting to me his Driver's License No. 18158450
issued in DFA Manila 2021.
Doc. No.___________;                             
Page No.___________;                              NOTARY PUBLIC for Cebu City
Book No.__________;                               Commission Serial No.______
Series of 2021.                                            Until December 31, 2021