REPUBLIC OF THE PHILIPPINES 9th Judicial Region METROPOLITAN TRIAL COURT City of Zamboanga Branch 1 SUR-AINA ISMAEL Plaintiff,

- versus ABBAS BARANG, Defendant. x ----------------------------------- x COMPLAINT COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most respectfully avers: 1. Plaintiff, SUR-AINA ISMAEL is of legal age, Filipino citizen, single, with residence and postal address at 331 HB Homes Subdivision, Sinunuc, Zamboanga City; Defendant ABBAS BARANG is a Filipino, of legal age, single and currently resident of 888 Star Apple Drive, Baliwasan, Zamboanga City, where he may be served with summons and other pertinent processes. 2. Plaintiff owns that property located at 888 Star Apple Drive, Baliwasan, Zamboanga City which it leased to defendant under the terms and conditions stated in the Contract of Lease dated 5 March 2010, which contract expires on 6 January 2011. A copy of the contract is attached as ANNEX A. 3. Upon expiration of the contract, plaintiff informed defendant of its intention not to renew the lease as it would use the property to construct storage facilities for its business; plaintiff then asked defendant to vacate the premises. A copy of plaintiffs 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 plaintiffs consent. Resort to the Barangay conciliation system proved useless as defendant refused to appear before the Lupong Tagapamayapa. A Certification to File Action is attached as ANNEX C. 5. Defendants act of dispossession has caused plaintiff to suffer material injury because the construction of plaintiffs storage facilities could not be started despite the arrival of materials at said property. Defendants continued occupation of the premises has also forced plaintiff to sue and to incur legal expenses amounting to Fifty Thousand Pesos (P50,000.00). WHEREFORE, plaintiff respectfully prays for judgment in its favor by ordering defendant to vacate the property and peacefully turn over possession to plaintiff and for defendant to pay plaintiff the amount of Fifty Thousand Pesos (P50,000.00) as compensation for the delay of the construction of the storage facilities and Fifty Thousand Pesos (P50,000.00) for Attorneys fees. Other just and equitable reliefs are also prayed for. Zamboanga City; November 10, 2012. Civil Case No. 3333 For: Ejectment

Fharhana M. Abdurahim PTR No. 107654/12-22-11/Zamboanga City IBP No. 55345/2-5-12/Zamboanga City Roll of Attorney No. 118765 Unit 101, Zenith Tower I Veterans Avenue, Zamboanga City

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING I, Sur-aina Ismael, of legal age, do hereby state that: I am the owner of the property located at 888 Star Apple Drive, Baliwasan, Zamboanga City in such capacity, caused this Complaint to be prepared; I have received a copy of the [Order/Resolution/Decision] of the Court on 15 June 2012; 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. SUR-AINA ISMAEL Complainant

IN WITNESS WHEREOF, I have signed this instrument on ___ day of November, 2012 in the city of Zamboanga, affiant exhibiting to me her Drivers License No. 5566 issued by the Land Transportation Office on January 10, 2012 at the City of Zamboanga.

Fharhana M. Abdurahim PTR No. 107654/12-22-11/Zamboanga City IBP No. 55345/2-5-12/Zamboanga City Roll of Attorney No. 118765 Unit 101, Zenith Tower I Veterans Avenue, Zamboanga City

Doc. No. ________ Page No. _______ Book No. _______ Series of 2012.