Republic of the Philippines

MUNICIPAL TRIAL COURT

Branch 01, Cabanatuan City
MANG KANOR
Plaintiff

-versus-

Civil Case No. 321654

For: Ejectment

PETER SICAT,
Dependant
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x
COMPLAINT
PLAINTIFF, by counsel, respectfully states that:
The Parties
1. Plaintiff is a Filipino, of legal age, and resident of #123 Sta.Rosa, Nueva Ecija

2. Defedant is also a Filipino, of legal age and resident of #123 Cabanatuan City,
Nueva Ecija, where he may be served with summons and other processes.
The Facts
1. Plaintiff owns that property located at No. 123 Umay street, Brgy. Bitas,
Cabanatuan City, which it leased to defendant under the terms and conditions
stated in the Contract of Lease dated December 20, 2014, which contract expired
on December 20, 2015. A copy of the contract is attached as ANNEX A and
made an integral part of this complaint.
2 The lease contract of the respondent for the occupation of the building will be
terminated on December 31, 2012 and no intention to renew or extend;

3. During the course of the respondents occupation of the said apartment, respondent
has failed to pay her rentals for the months of August, September,

4. Respondent has continued to occupy the said apartment notwithstanding the fact that
he failed to pay the lease for two (2) consecutive months violating the Contract of Lease
agreement thus depriving the plaintiff from having the said apartment leased by other
persons;
5. Several demands to vacate was made by plaintiff to respondent, although orally, but
respondent refused to vacate the said apartment and return possession to the plaintiff;
6. On September 22, 2015, plaintiff sent a letter to respondent as a last and final demand
for respondent to vacate plaintiffs apartment; (Copy of Demand Letter is hereto attached as
Annex B)
7. Until now Respondent still refuse to vacate and restore possession and pay his rentals
for the months of August, and September, 2014 during his occupation of the apartment;
8. Thus, Respondent is unlawfully withholding possession of the subject apartment
from the plaintiff despite last and final demand, to the damage and prejudice of the
plaintiff;
9.Before filing of this complaint, the dispute has been referred to the Lupong
Tagamayapa of Cabanatuan City but the parties failed to arrive at an amicable
settlement; (Certificate to File Action is hereto attached as Annex C)

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 (P 20,000.00) PHILIPPINE
CURRENCY, representing the arrears of rent now overdue.
3. To pay the costs for this suit.

Other reliefs just and equitable under the premises are likewise prayed for.
Cabanatuan City, Philippines, November 29, 2015.

MINI LAW OFFICE

Counsel for Plaintiff
Rm. 123, 21rd Floor, Very small Building,
Cabanatuan City

By:

ATTY. BUY N. SEHL

PTR No: 0116199 (2016)
IBP No.:101682 (2016)
MCLE Compliance No.: III-0025943 (2016)
Roll No.: 246951