Complaint For Unlawful Detainer

REPUBLIC OF THE PHILIPPINES
FOURTH JUDICIAL REGION

MUNICIPAL CIRCUIT TRIAL COURT
Taal-San Nicholas, Batangas
SUSAN ROXAS
Plaintiff,
Civil Case No. 3756
-versus- Unlawful Detainer
with Damages
SPOUSES JUAN AND ESTELLA BERNABE

Respondents.
x-----------------------------------------x
COMPLAINT
PLAINTIFF, by counsel, and unto this Honorable Court,
most respectfully allege: THAT
1. Plaintiff is of legal age, Filipino, with residence and postal
address at No. 45, Brgy. Aplaya, Lemery, Batangas where she
may be served notices and other court processes;
2. Respondents are of legal age, Filipino, with residence and
postal address at Butong, Taal, Batangas;
3. Plaintiff is the absolute owner of a 500 sqm parcel of lot
situated at Butong, Taal, Batangas with TCT No. 1234 under
the name of the plaintiff issued by Register of Deeds of Taal,
Batangas. (Annex A) The 85 sqm parts of the subject lot were
occupied by the respondents by mere tolerance of the previous
owner since 2010 and plaintiff as the new owner who bought it
from spouses Jose and Maria Castillo last 2012;
4. As agreed by the parties that the respondents will
immediately vacate the lot area that they were occupying and
will remove the improvements that they introduce therein
upon demand of the plaintiff as the lawful owner;
5. On May 20, 2020, the plaintiff, with assistance of a
counsel, sent a demand letter (Annex B) to the respondents to
vacate the lot and remove all the improvements that
introduced therein within five days;
6. On May 25, 2020, at the expiration of the five (5) days
grace period given by the plaintiff, the respondent still has not
removed the improvements they introduced on the lot and his
consistently refused to vacate the premises;
7. Until now, respondent still refuse to vacate and restore
the lot from its original status.
8. Thus, respondent is unlawfully withholding possession of
the subject lot from the plaintiff despite last and final demand,
to the damage and prejudice of the plaintiff;
9. Before filing this complaint, the dispute has been referred
to the Lupong Tagapamayapa of Butong, Taal, Batangas but
the respondent failed to appear, hence, no amicable settlement
was made. Certificate to file action is hereby attached as
(Annex C).
PRAYER
WHEREFORE, WITH ALL THE FOREGOING, it is

respectfully prayed unto this Honorable Court that judgment
be rendered in favor of Plaintiff:
1. Ordering the respondents to vacate the subject
property;
2. Ordering the respondents to pay the plaintiff the
amount of Four Thousand Pesos (Php 4,000.00) as
reasonable compensation for the use of the subject
property from May 2020, until the same is vacated and
restored to the plaintiff;
3. Ordering the respondents to pay the amount of
Twenty Five Thousand Pesos as attorney’s fees;
4. Ordering the respondents to pay the plaintiff, Fifty
Thousand Pesos (Php 50,000.00) by way of moral
damages;
5. Ordering the respondents to pay the cost of the suit.
Other reliefs just and equitable under the premises are

likewise prayed for.
Taal, Batangas, Sept. 17, 2020.
ARMAN D ALIPIT JR.
Counsel for the Plaintiff
Notary Public for and in the Municipalities of
Bauan, Mabini, and Taal, Batangas
Commission No. 2018-99
Until December 31, 2020
Roll of Attorneys No. 003780
IBP Lifetime No. 0987680/Batangas City
MCLE Compliance No. V-09090878,07-11-17
TIN: 200-100-999
VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
REPUBLIC OF THE PHILIPPINES

LEMERY, BATANGAS) S.S.
I, SUSAN ROXAS, of legal age, after having been duly

sworn in accordance with law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
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;
4. I have not commenced any other action or proceeding

involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or

proceeding has been filed or is pending before the Supreme
Court, the Court of Appeals, or any other tribunal or agency, I
undertake to report that fact within five (5) days therefrom to
this Honorable Court.
Lemery, Batangas September 22, 2020

SUSAN ROXAS
Affiant
SUBSCRIBED AND SWORN to before me this 31st day of

March 2016 at Cavite City, Philippines affiant exhibiting to me
her Passport No. 58158450 issued in DFA Manila 2014.
ATTY. DINA MALABO

Notary Public
Municipality of Taal and Lemery Batangas
Commission No. 2019-89
Until December 31, 2021
Roll of Attorneys No. 69696
IBP Lifetime No. 0987680/Batangas City
MCLE Compliance No. V-09090009,09-11-19
TIN: 999-111-111
Doc. No.____
Page No. ____
Book No. ____
Series of 2020

Complaint For Unlawful Detainer

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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

SPOUSES JUAN AND ESTELLA BERNABE

WHEREFORE, WITH ALL THE FOREGOING, it is

Other reliefs just and equitable under the premises are

VERIFICATION AND CERTIFICATION OF NON-FORUM

REPUBLIC OF THE PHILIPPINES

I, SUSAN ROXAS, of legal age, after having been duly

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

4. I have not commenced any other action or proceeding

5. To the best of my knowledge and belief, no such action or

6. If I should thereafter learn that a similar action or

Lemery, Batangas September 22, 2020

SUBSCRIBED AND SWORN to before me this 31st day of

ATTY. DINA MALABO

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