Complaint For Forcible Entry
Complaint For Forcible Entry
A & B,
Plaintiffs,
Civil Case No. Q-47585
-versus- For: Ejectment (Forcible
Entry)
C,
Defendant.
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COMPLAINT
1. Plaintiffs A & B are residing at #564 Anonas Street, Brgy. 630, Sta.
Mesa Manila, where they may be served with court order and other
processes;
LEASE CONTRACT
1
Subdivision, Congressional Ave., Quezon City, herein after
referred to as the LESSOR;
-AND-
WITNESSETH; That
2
At the expiration of the term of this lease or cancellation
thereof, as herein provided, the LESSEE will promptly deliver to
the LESSOR the leased premises with all corresponding keys
and in as good and tenable condition as the same is now,
ordinary wear and tear expected devoid of all occupants,
movable furniture, articles and effects of any kind. Non-
compliance with the terms of this clause by the LESSEE will
give the LESSOR the right, at the latter's option, to refuse to
accept the delivery of the premises and compel the LESSEE to
pay rent therefrom at the same rate plus Twenty (20) % thereof
as penalty until the LESSEE shall have complied with the terms
hereof. The same penalty shall be imposed in case the LESSEE
fails to leave the premises after the expiration of this Contract of
Lease or termination for any reason whatsoever.
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6. When the lease expired on September 24, 2020, the Defendant asked
the Plaintiffs to vacate the premises.
7. The Plaintiffs refused such notice to vacate because they have already
notified their intention to renew the lease to the Defendant, to which
the latter agreed as evidenced by the written agreement between the
parties. (Written Agreement for Renewal of Lease Agreement is
hereby attached as Annex “B”)
3
WHEREAS, the LESSOR agrees to such extension
for another FIVE YEARS from expiration of the first lease
agreement: from September 24, 2020 to September 24,
2025;
9. About a month after, the Defendant, with the aid of armed men,
caused the closure of the warehouse by constructing fences around the
property, in violation of the renewed lease agreement;
PRAYER
Plaintiff prays for such other reliefs as may be deemed just and equitable
under the circumstances.
2. That the allegations in the pleading are true and correct based on
our personal knowledge and authentic documents;
Doc. No. 4
Page No. 2
Book No. I
Series of 2020
Copy Furnished