Form18-Complaint For Ejectment
Form18-Complaint For Ejectment
- versus -
x---------------------------------------x
COMPLAINT
3. The plaintiff is the owner and Lessor of the leased premises - a two-
storey apartment unit located at Unit A JBL Building, McArthur
Highway, Salapungan, Angeles City, as shown in TCT No. 23245,
attached herein as ANNEX “A”;
4. The defendant is the lessee of the house unit that is owned by the
plaintiff as evidenced by the written contract of lease that both parties
signed on January 1, 2019, and said contract is attached herein as
ANNEX “B”;
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8. Upon failure of the defendant to vacate, the plaintiff sent on January 5,
2020 a Letter demanding the defendant to vacate the leased property,
attached herein as ANNEX “C”;
9. The written demand was duly received by the defendant who affixed
his signature thereon. The plaintiff made an oral follow-up demand on
January 6, 2020;
10. Despite several oral and written demands by the plaintiff, the defendant
failed to vacate the leased premises;
11. The plaintiff was constrained to file an action with the Lupong
Tagapamayapa of Barangay Salapungan, Angeles City on January 7,
2020;
13. The defendant’s refusal to vacate the premises of the subject property
has deprived plaintiff to hold possession and beneficial use of the
property for which plaintiff has incurred damages for rentals he should
have earned;
14. Due to the defendant’s malicious and wanton refusal to vacate the
property in suit and failure to appear in the conciliation proceedings
before the Barangay’s Lupon, plaintiff was constrained to hire the
services of a lawyer to protect his rights and interests for a fee of Fifty
Thousand Pesos (₱50,000.00) for which defendant should be made
answerable to plaintiff.
PRAYER
Other reliefs just and equitable under the circumstances are likewise
prayed for.
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IN WITNESS WHEREOF, I have hereunto affixed my signature this
3rd day of April 2020, at Angeles City, Pampanga, Philippines.
Iris Galecio
IRIS GALECIO
Counsel for the Plaintiff
Roll of Attorney No: 88888
PTR No: 12345678 / 1-8-2020
IBP No: 87654321 / 1-8-2020
MCLE Comp. No.: III-0011223
3. I have read the contents thereof and the facts stated therein are
true and correct of my personal knowledge and/or on the basis of
copies of documents and records in my possession;
J.Santos
JOSE SANTOS
Affiant
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SUBSCRIBED AND SWORN to before me this 3rd day of April
2020 at Angeles City, Pampanga, Philippines, affiant exhibiting to me his
Driver’s License No. 12345 issued by the Land Transportation Office in
Angeles City on October 20, 2019.
SM
SAMANTHA MORALES
Notary Public of Angeles City
Until December 31, 2020
Roll of Attorney No: 88888
PTR No: 12345678 / 1-8-2020
IBP No: 876543 / 1-8-2020
MCLE Compliance No.: III-0011223
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