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: [1] to vacate the property and
peacefully turn over possession to plaintiff; [2] 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
[3] 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.