Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

FIRST JUDICIAL REGION
Branch 2
Baguio City
CIVIL CASE NO.: 23567
Plaintiff,
- versus -

FOR: FORCIBLE ENTRY

Defendant,

x--------------------- ---x
COMPLAINT

COMES NOW, the plaintiff through undersigned

counsel, and to this Honorable Court respectfully alleges:
1. The plaintiff is of legal age, Filipino citizen,
single and with residence at No. 123 P.
Burgos, Baguio City within the jurisdiction of
this Honorable Court, where he may be served
with notices and processes of the Honorable
Court;
2. Defendant, is of legal age, Filipino citizen,
married and a resident of No. 234 Lower
Magsaysay, Baguio City where he may be
served with summons, notices, orders and
other processes of the Honorable Court;
3. That defendant is the landlord of the boarding
house located at No. 23 P. Burgos, Baguio
City;
4. That plaintiff has been leasing on the said
boarding house of the defendant for two years
now and the monthly rentals of three
thousand pesos (P3,000.00) have been
regularly been paid. The one month deposit
one month advance policy of the leasing term
has been consistently complied with;

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5. That on February 1, 2016, the defendant went

to the plaintiffs boarding space and asked
him to vacate the property immediately
despite having paid already his rental for the
period of February and March 2016;
6. That on February 6, 2016, while the plaintiff
was not around being at work, the defendant
forcibly opened the plaintiffs room and
moved out the plaintiffs belongings;
7. That the removal bringing out of the plaintiffs
properties resulted to the damage of the
plaintiffs precious figurine that has a fair
market value amounting to P25,000.00 and
the breaking of the porcelain vase amounting
to P12,000.00.
8. Aggrieved by the defendants action, the
plaintiff engaged the services of the
undersigneds Law Office for which she agreed
to pay attorneys fees in the amount of
TWENTY THOUSAND (Php 20,000.00) PESOS
representing acceptance fee and TWO
THOUSAND ( PHP 2,000.00) PESOS per court
appearance;
PRAYER
WHEREFORE and in view of the foregoing, it is most
respectfully prayed that, after hearing, judgment be
rendered:
1. To issue an order in favor of the plaintiff and
against the defendant ordering the latter to allow
the plaintiff to stay in the premises till the end of
March 2016 of which the plaintiff had already
advanced his rentals to said month;
2. To mandate the defendant to desist from bothering
the plaintiff while said lease term has not yet
lapsed;
3. To pay for the actual damages done totaling
P37,000.00 which are the costs of the figurine and
the vase destroyed by the act of the defendant;

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4. To order the defendant to pay the plaintiff the

amount of P20,000.00 by way of lawyers
acceptance fee and P2,000.00 per court
appearance;
Such other relief just and equitable under the premises is
likewise prayed for.
Baguio City, Philippines this 15th day of March 2013.

Counsel for Plaintiff

No. 23, Otek Square, Otek Street, Baguio City
Roll No. 65321; April 10, 2015
PTR No. 2091162; January 10, 2016, Baguio City
IBP No. 2311755; January 15, 2016, Baguio-Benguet Chapter
M.C.L.E. Compliance No. III-098765, January 11, 2015, Pasig
City
Doc. No.1;
Page No. 2;
Book. No. II;
Series of 2016.

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VERIFICATION & CERTIFICATION AGAINST FORUM

SHOPPING
Republic of the Philippines )
Baguio City
) S.S.
I, , of legal age, Filipino citizen, single and resident of No.
123 P. Burgos, Baguio City, after having been duly sworn to
in accordance with law do hereby depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing
complaint and have read the allegations contained
therein;
3. The allegations in the said complaint are true and
correct of my own knowledge and authentic records;
4. I hereby certify that I have not commenced any other
action or proceeding involving the same issues in any
court, tribunal or quasi-judicial agency and, to the
best of my knowledge, no such other action or claim
is pending therein;
5. That if I should learn thereafter that a similar action
or proceeding has been filed or is pending, I hereby
undertake to report that fact within five (5) days
therefrom to the court or agency where the original
pleading and sworn certification contemplated herein
have been filed;
6. I executed this verification/certification to attest to
the truth of the foregoing facts and to comply with
the provisions of Adm. Circular No. 04-94 of the
Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 15th of March 2016, in the City of Baguio.

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SUBSCRIBED AND SWORN to before me this 15 day

of March, 2016, in City of Baguio.
Notary Public
Notarial Commission expires on December 31, 2017
Roll No. 65321; April 10, 2015
PTR No. 2091162; January 10, 2016, Baguio City
IBP No. 2311755; January 15, 2016, Baguio-Benguet Chapter
M.C.L.E. Compliance No. III-098765, January 11, 2015, Pasig
City
Cell No. 09-123-456-789, TIN: 321-654-000
Doc. No.1;
Page No. 2;
Bk. No. II;
Series of 2016.

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