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Republic of the Philippines

Municipal Trial Court


Quezon City
DIGONG,
Petitioner,
-

Civil Case No. 04321


For: Unlawful Detainer

Versus -

BONIFACIO AND CORDAPIA,


Defendant,
x--------------------------------------------x
COMPLAINT FOR UNLAWFUL DETAINER
PLAINTIFF thru counsel, unto this Honorable Court respectfully alleges that:
1. The PLAINTIFF is of legal age and a resident of Manila City and the
DEFENDANTS are also of legal age and residents of Quezon City where they may
be served with the summons;
2. Bonifacio, a defendant, occupies a unit valued at 2.5M under a rent-to-own contract,
leased his unit to Cordapia, defendant.
3. The plaintiff and defendants executed a contract stipulating that Cordapia, a
defendant shall occupy the unit provided that Digong, the plaintiff shall religiously
comply with his rental obligations.
4. The plaintiff left for an overseas trip to last for about six(6) months and he
nevertheless remained faithful to the payment of his rental dues.
5. The plaintiff is the one paying for the unit as Bonifacio, defendant merely pays to the
owner of the Condominium only after the defendant receives the plaintiffs payment.
P R AY E R
WHEREFORE, it is respectfully prayed that after due hearing, judgement be rendered
in favour of the plaintiff:
a) For the restitution of the above mentioned premises; and
b) For the payment of the amount needed as compensation for the reasonable use
of the subject premises until they finally vacate the said premises, and costs of
suit
Other forms of relief just and equitable under the premises are likewise prayed for.
Quezon City, Philippines, this 18th of September 2015
ATTY. RAFAELLA DAYE T. TAN
Counsel for the Plaintiff
PTR No. 98765432:4-26-15:QC
IBP No. 123456:4-26-15:QC
Roll No. 99011:5-10-10: Manila
CSG Building, Room 105
Quezon City

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING


Republic of the Philippines )
City of Quezo
)S.S.
I, Digong, of legal age, do hereby state that: I am the plaintiff in the
pleading/document entitled UNLAWFUL DETAINER and in such capacity, caused
this Complaint to be prepared; I have read its consent 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 18th of September 2015,
in the City of Quezon.
_____________________
DIGONG
Plaintiff

SUBCRIBED AND SWORN to before me in the City of Quezon on 18 th of September 2015,


affiant exhibiting before me his Government Issued ID no. 1234567 issued on 15th of May 2014
at Manila.

ATTY. RAFAELLA DAYE T. TAN


Counsel for the Plaintiff
PTR No. 98765432:4-26-15:QC
IBP No. 123456:4-26-15:QC
Roll No. 99011:5-10-10: Manila
CSG Building, Room 105
Quezon City
Doc. No. __________
Page No.___________
Book No.___________
Series of 2015