REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
BRANCH ___
QUEZON CITY

IAN ALBA, Civil Case No. _____________

Plaintiff, FOR: UNLAWFUL
DETAINER WITH
- versus - DAMAGES

JUN MIRANDA,
Defendant.
x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court,

hereby respectfully avers:

1. That plaintiff is of legal age, Filipino, single, and a resident of

Crowdy Bay, Blue Cross Subdivision, Quezon City, Philippines, while the
defendant is also of legal age, single, Filipino and a resident of No. 9 West
Aguila, Green Cross Subdivision, Quezon City, Philippines where summons
and court processes may be served;

2. That Plaintiff the absolute owner and lessor of the house and lot
situated at No. 9 West Aguila, Green Cross Subdivision, Quezon City and
now leased and occupied by the respondent;

3. That Defendant leases and occupies the said property as agreed upon
between the plaintiff and the respondent in the lease contract executed on
April 01, 2017 under the express obligation to pay a monthly rental of Php
50,000.00; (Copy of Contract of Lease is hereto attached as Annex “A”)

4. That during the course of the Defendant’s occupation of the said

property, Defendant has failed to pay his rentals for the months of October,
November, and December 2017, and January, February and March, 2018;

5. That despite Plaintiff's repeated demands, both written and verbal,

defendant failed, neglected and refused to fulfill his obligations without just
and valid grounds to the continued damage and prejudice of plaintiff, as
evidenced by Annexes “B”, “B-1”, and “B-2”
 6. That Defendant is unlawfully withholding possession of the subject
property from the plaintiff despite last and final demand, to the damage and
prejudice of the Plaintiff;

7. Before filing of this complaint, the dispute has been referred to the
Lupong Tagamayapa of Quezon City but the parties failed to arrive at an
amicable settlement.

WHEREFORE, premises considered, it is hereby respectfully prayed

before the Honorable Court that after due notice and hearing, judgment be
rendered in favor of Plaintiff:

a. For the restitution of the abovementioned property;

b. For the payment of rental for six (6) months plus interest; and

c. To pay the costs of this suit.

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

Iloilo City, April 16, 2018.

ATTY. LOVELY L. DE LA TORRE

De La Torre Law Office, 8th Floor,
Excelsior Bldg., Sampaloc, Manila
Roll of Attorneys No. 19283
PTR NO. 2651863, 05/17/17, Manila
IBP NO. 2122, 05/17/17, Manila
REPUBLIC OF THE PHILIPPINES)
QUEZON CITY) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, IAN ALBA, of legal age, Filipino, married, and a resident of

Crowdy Bay, Blue Cross Subdivision, Quezon City, Philippines, after being
sworn in accordance with law, hereby depose and say:

(1) That I am the Plaintiff in the above-entitled case;

(2) That I have caused the preparation of the above Complaint and I
have read the same and understood the contents thereof;

(3) That the allegations contained therein are true and correct of my
own personal knowledge and based on authentic records.

(4) That I further certify that: I have not theretofore commenced any
other action or proceeding or filed any claim involving the same issues or
matter in any court, tribunal, or quasi-judicial agency and, to the best of my
knowledge, no such action or proceeding is pending therein; if I should
thereafter learn that the same or similar action or proceeding has been filed or
is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5)
days therefrom to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 16th

day of April, 2018 at Quezon City, Philippines.

IAN ALBA
Affiant
 SUBSCRIBED AND SWORN to before me, this 16th day of April,
2018 affiant exhibiting to me his Tax Identification Card as shown above
below his name as competent evidence of his identity.

ATTY. LOVELY L. DE LA TORRE

Notary Public for and in the City of Manila
My Commission No. is 28
Expires on December 31, 2019
De La Torre Law Office, 8th Floor,
Excelsior Bldg., Manila
Roll of Attorneys No. 19283
PTR NO. 2651863, 05/17/17, Manila
IBP NO. 2122, 05/17/17, Manila

Doc. No. 4;
Page No. 2;
Book No. 1;
Series of 2017;