Republic of the Philippines METROPOLITAN TRIAL COURT National Capital Judicial Region Quezon City, Branch ___ JUAN DELA CRUZ, Plaintiff, Civil Case No. ____ For: Ejectment - versus BERNARDO CARPIO and all Others claiming under him, Defendant. x ----------------------------------- x COMPLAINT PLAINTIFF, by counsel, to this Honorable Court, respectfully alleges that: 1. Plaintiff is a Filipino, of legal age, single and currently resident of 14 Malakas Street, Quezon City; Defendant is a Filipino, of legal age, single and currently a resident of 12 Maganda Street, Quezon City, where he may be served with summons and other pertinent processes. 2. Plaintiff owns that property located at 12 Maganda Street, Quezon City which he leased to defendant under the terms and conditions stated in the Contract of Lease dated 1 January 2020, which contract expires on 31 December 2020. A copy of the contract is attached as ANNEX A. 3. Upon expiration of the contract, plaintiff sent defendant to a letter demanding that he vacate the property within 10 days from his receipt of the demand letter. A copy of plaintiff’s letter to defendant is attached as ANNEX B. 4. Despite demand duly made and received, defendant has refused to vacate the premises and continues to occupy the property without plaintiff’s consent. 5. Parties went through the Barangay conciliation proceeding but they failed to enter into an amicable settlement. A Certification to File Action is attached as ANNEX C. 6. Defendant’s failure to vacate the property caused damage to plaintiff because the latter is denied possession and use of the property. 7. The fair monthly rental value of the property is =P= 50,000.00 per month. 8. Defendant’s continued occupation of the premises has also forced plaintiff to sue and to incur legal expenses amounting to not less than Twenty Thousand Pesos (=P= 20,000.00). PRAYER WHEREFORE, plaintiff respectfully prays for judgment in its favor by ordering defendant:  to vacate the property and peacefully turn over possession to plaintiff;  to pay =P= 50,000.00 per month as fair monthly rental value of the property from date of demand up to the day the property is turn-over to the plaintiff and  to pay plaintiff the amount of Twenty Thousand Pesos (=P= 20,000.00) for Attorney’s fees. Other just and equitable reliefs are also prayed for. Makati for Quezon City; 8 March 2021. JOHN X. JURISPRUDENCIA Counsel for Plaintiff 4 J. P. Rizal Street, Makati City IBP No._______________ PTR. No. ____________ Roll of Attorneys No. MCLE Compliance No. Telephone No. E-mail Address: VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING I, JUAN DELA CRUZ, of legal age, do hereby state that: I am the plaintiff in the above-captioned case; I caused this Complaint to be prepared; I have read its contents and affirm that they are true and correct to the best of my own personal knowledge; I hereby certify that there is no other case commenced or pending before any court involving the same parties and the same issue and that, should I learn of such a case, I shall notify the court within five (5) days from my notice. IN WITNESS WHEREOF, I have signed this instrument on _____________. JUAN DELA CRUZ SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day of _________________, affiant exhibiting before me his ______________ Identification Card No. _______________ issued on __________________ at _____________________ valid up to _______________ as his competent means of identification. (Sgd.) JOHN Y. TORIO Notary Public Until __________________ PTR No. _______________ Issued at ______________ On ___________________ Doc. No. Page No. Book No. Series of 2021.