REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

FIRST JUDICIAL REGION
Branch 5
City of Baguio

JUAN DELA CRUZ,

Plaintiff,
CIVIL CASE No. 12345
-versus- FOR: Unlawful Detainer

JOSE BONIFACIO,
Defendant.

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COMPLAINT

PLAINTIFF, thru the undersigned counsel and unto this Honorable Court, most respectfully
allege, that:

1. The plaintiff, JUAN DELA CRUZ, is of legal age, Filipino citizen, single, with residence and
postal address at Governor Pack Road, Baguio City;
2. That the defendant, JOSE BONIFACIO, is of legal age, Filipino citizen, single, with residence
and postal address at Bonifacio St., Baguio City, where they may be served with summons
and other court processes;
3. The plaintiff is the owner of a land over which an apartment had been constructed located at
123 Governor Pack Road, Baguio City;
4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid apartment
for a consideration of P7,000.00 a month as rental to be paid within the first ten (10) days of
each month starting January 1, 2017;
5. The defendant failed to pay the agreed rental for several months starting February 10, 2017
up to the present;
6. On May 11, 2017, the plaintiff sent a letter of demand to vacate the apartment which was
received by the defendant as shown in the registry return receipt hereto attached as Annex
“A”;
7. Despite said letter of demand which was repeated by oral demands, the defendant failed and
still refused to pay the agreed amount of rentals and to vacate the apartment;
8. By reason of failure of the defendant to vacate the premises and to pay the unpaid rentals, the
plaintiff was compelled to file this complaint engaging the services of counsel in the amount of
P10,000.00.

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court
that, after hearing, judgment be rendered ordering the defendant:

1. To vacate the subject premises;

2. To pay the amount of P7,000.00 per month as compensation for the reasonable use of the subject
premises until they finally vacate the said premises;
3. To pay the plaintiff the cost of the suit.

Baguio City, this day of 9th, March 2018.

MARIA CLARA
Counsel for the Plaintiff
Unit 123, H Tower
Mary Heights, Bakakeng, Baguio City
Roll No. 12345, May 10, 2001
IBP No. 12345/02-05-17/Manila
PTR No. 87654/12-22-17/Manila
Baguio-Benguet Chapter
Republic of the Philippines )
City of Baguio ) S.S.

VERIFICATION AND CERTIFICATION

I, JUAN DELA CRUZ, of legal age, Filipino citizen, single and resident of 123 Governor Pack
Road, 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 and certification to attest to the truth of the foregoing facts and to comply
with the provisions of Administrative Circular No. 04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 9th of March 2018, in the
City of Baguio.

JUAN DELA CRUZ

Affiant

SUBSCRIBED AND SWORN to before me this 9th day of March 2018, in the City of Baguio,
affiant exhibiting to me his Driver’s License No. 12345 issued by the Land Transportation Office on
January 1, 2017 at the City of Baguio.

MARIA CLARA
Notary Public
Until December 31, 2019
Roll No. 789101, May 10, 2001
IBP No. 12345/02-05-17/Manila
PTR No. 67891/12-22-17/Manila
Baguio-Benguet Chapter

Doc. No. ________

Page No. _______
Book No. _______
Series of 2018.