4.1 Complaint For Ejectment.docx

REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT City of Manila Branch 1 IAN ALBA, Plaintiff, -versus-

CIVIL CASE No. 345678 FOR: Unlawful Detainer

JUN MIRANDA, Defendant. x-----------------------------------x COMPLAINT COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most respectfully avers: 1. That the plaintiff, IAN ALBA, is of legal age, Filipino citizen, single, with residence and postal address at 123 Benitez Street, Manila; 2. That the defendant, JUN MIRANDA, is of legal age, Filipino citizen, single, with residence and postal address at No. 9 West Aguila, Green Cross Subdivision, Quezon City where they may be served with summons and other court processes; 3. The plaintiff is the owner of a land over which a house had been constructed located No. 9 West Aguila, Green Cross Subdivision, Quezon City; 4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid house for a consideration of P50,000.00 a month as rental to be paid within the first day of each month starting May 1, 2006; 5. The defendant failed to pay the agreed rental for six months starting January 1, 2007 to June 30, 2007; 6. On July 3, 2007, the plaintiff sent a letter of demand to vacate the apartment which was received by the defendant as shown in the registry return receipt hereto attached as Annex “A”; 7. Despite said letter of demand which was repeated by oral demands, the defendant failed and still refused to pay the agreed amount of rentals and to vacated the apartment; 8. By reason of failure of the defendant to vacate the premises and to pay the unpaid rentals, the plaintiff was compelled to file this complaint engaging the services of counsel in the amount of P10,000.00. WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that, after hearing, judgment be rendered ordering the defendant: 1. To vacate the subject premises; 2. To pay the amount of P50,000.00 per month as compensation for the reasonable use of the subject premises until they finally vacate the said premises;

3. To pay the plaintiff the cost of the suit. City of Manila, August 24, 2007. RAMOS LAW OFFICE Counsel for the Plaintiff Unit 123, Victoria Tower I Taft Avenue, Manila By: Louise Reyes Roll of Attorney No. 98765 IBP No. 12345/2-5-12/Manila PTR No. 87654/12-22-11/Manila