Unlawful Detainer Complaint.docx

REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT City of Manila Branch 1 KRUL ACOSTA, Plaintiff, CIVIL CASE No. 98765 -versus-

FOR: Unlawful Detainer

MEGAN VITUG, Defendant.

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COMPLAINT COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most respectfully avers: 1. That the plaintiff, KRUL ACOSTA, is of legal age, Filipino citizen, single, with residence and postal address at 123 Benitez Street, Manila; 2. That the defendant, MEGAN VITUG, is of legal age, Filipino citizen, single, with residence and postal address at 456 Modesto Street, Manila, where they may be served with summons and other court processes; 3. The plaintiff is the owner of a land over which and apartment had been constructed located 654 San Pedro Street, Manila; 4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid apartment for a consideration of P5,000.00 a month as rental to be paid within the first ten (10) days of each month starting November 3, 2011; 5. The defendant failed to pay agreed rental for several months starting February 19, 2012 up to the present; 6. On May 3, 2012, 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 complain 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 P5,000.00 per month as compensation for reasonable use of the subject premises until they final vacate the said premises; 3. To pay the plaintiff the cost of the suit City of Manila, September 24, 2012. REYES, TOLENTINO AND CRUZ LAW OFFICE Counsel for the Plaintiff Unit 123, Victoria Tower I Taft Avenue, Manila By: Louise Reyes Roll of Attorney No. 98765 IBP No. 1234/2-5-12/Manila PTR No. 87654/12-22-11/Manila