Complaint For Unlawful Detainer
Complaint For Unlawful Detainer
SUSAN ROXAS
Plaintiff,
Civil Case No. 3756
-versus- Unlawful Detainer
with Damages
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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
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;
Doc. No.____
Page No. ____
Book No. ____
Series of 2020