Complaint Ejectment Sample

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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


City of Malolos Bulacan

JOANE ROSE D. MACLANG,


Plaintiff,

-versus-

CIVIL CASE NO. 4321


FOR: EJECTMENT

MARI FRANZ V. PAHATI,


Defendant,
x- - - - - - - - - - - - - - - - - - - - - x

COMPLAINT
COMES NOW, the plaintiff together with the undersigned counsel to
this most Honorable Court, MOST RESPECTFULLY STATES THAT;
1. That the plaintiff JOANE ROSE D. MACLANG, is of legal age
single, Filipino Citizen, with residence and postal address at 111
Pinagbakahan, Malolos, Bulacan;
2. That the defendant is MARI FRANZ V. PAHATI, is of legal age.
Filipino Citizen, single, with the residence and postal address at 228
Sitio 4 San Vicente, Paombong, Bulacan, which they may be served
with summons and other court processes;
3. That the plaintiff is the owner of Southeast Buildings, a rental
building company organized and existing under the laws of Republic
of the Philippines.
4. That the defendant leases and occupies in one of the building of the
plaintiff Southeast Buildings and express obligation of paying a rent
of One Hundred Thousand Pesos (100,000.00) per month and payable
within the first five (5) days of each month.

5. That the defendant has not paid the rents for the said building for the
months of October, November, and December 2009.
6. That the plaintiff has demanded the defendant to vacate the above
premises because the Contract of Agreement had already terminated
and to pay back his rents, now amounting to Three Hundred Thousand
Pesos (300,000.00), the last demand for payment having made to him
personally and in writing on 10 January 2014 or more than five (5)
days before filing of this complaint. A copy of the demand letter
received by the defendant is attached hereto as Annex A.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed that, after
due hearing judgment to be rendered in favor of the plaintiff.
a. For the restitution of the above-mentioned premises.
b. For the payment of (300,000.00) for the back rent of the defendant.
All other reliefs just and equitable under the premises are likewised prayed
for.
Malolos, Bulacan, Philippines, January 2014

ATTY. FRANCISCO S. REYES


Counsel for Plaintiff
143 Mojon, Malolos, Bulacan

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines )


Province of _____________

) S.S.

Municipality of __________

I, JOANE ROSE D. MACLANG, of legal age, Filipino citizen, single


with address at 111 PINAGBAKAHAN, MALOLOS, BULACAN, after

having been duly sworn to in accordance with law do hereby depose and
say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and
have read the allegations contained therein;
3. The allegations in the complaint are true and correct of my own
knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or
proceeding involving the same issues in any court, tribunal or quasijudicial agency and, to the best of my knowledge, no such other action
or claims are pending therein;
5. That if I should learn thereafter that a similar action or proceeding has
been filed or pending therein, I hereby undertake to report the fact
within five (5) days there from to the court or agency where the
original pleading and sworn certification contemplated herein having
been filed;
6. I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular
No. 04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have here unto affixed my signature this


___ of __________,_____ at _______________.
JOANE ROSE D. MACLANG

SUBSCRIBED AND SWORN to before me this __day of ___________,


_____, at _________, affiant exhibiting to me his
_______________________ issued by the _________.

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