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KRUL ACOSTA,
Plaintiff,
CIVIL CASE No. 98765
-versus- FOR: Unlawful Detainer
MEGAN VITUG,
Defendant.
x-----------------------------------x
COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most
respectfully avers:
That the plaintiff, KRUL ACOSTA, is of legal age, Filipino citizen, single, with residence and postal address at
123 Benitez Street, Manila;
That the defendant, MEGAN VITUG, is of legal age, Filipino citizen, single, with residence and postal address
at 456 Modesto Street, Manila, where they may be served with summons and other court processes;
The plaintiff is the owner of a land over which an apartment had been constructed located 654 San Pedro
Street, Manila;
By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid apartment for a
consideration of P5,000.00 a month as rental to be paid within the first ten (10) days of each month starting
November 3, 2011;
The defendant failed to pay the agreed rental for several months starting February 19, 2012 up to the
present;
On May 3, 2012, 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”;
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 vacated the apartment;
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:
By:
Louise Reyes
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila
I, KRUL ACOSTA, of legal age, Filipino citizen, single and resident of 123 Benitez Street, Manila, after
having been duly sworn to in accord Nance with law do hereby depose and say:
IN WITNESS WHEREOF, I have hereunto affixed my signature this 24th of September 2012, in the City of
Manila.
KRUL ACOSTA
SUBSCRIBED AND SWORN to before me this _______ day of September, 2012, in the City of Manila,
affiant exhibiting to me his Driver’s License No. 12345 issued by the Land Transportation Office on April 8,
2012 at the City of Manila.
ATTY. NO CASE
Notary Public
My Commission Expires Dec. 31, 2012
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila