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Ejectment Complaint - Legal Forms

This document is a complaint filed with the Municipal Trial Court of Quezon City by the plaintiff Rodeo Juliet against defendants Sps. Delos Reyes. The plaintiff alleges that the defendants leased a commercial space from the plaintiff but have failed to pay rent from June to November 2019. Despite demands to vacate, the defendants continue to unlawfully occupy the premises, depriving the plaintiff of income. The plaintiff is seeking restitution of the property, payment of 120,000 PHP in back rent plus interest, and court costs.

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Kathleen Cruz
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351 views2 pages

Ejectment Complaint - Legal Forms

This document is a complaint filed with the Municipal Trial Court of Quezon City by the plaintiff Rodeo Juliet against defendants Sps. Delos Reyes. The plaintiff alleges that the defendants leased a commercial space from the plaintiff but have failed to pay rent from June to November 2019. Despite demands to vacate, the defendants continue to unlawfully occupy the premises, depriving the plaintiff of income. The plaintiff is seeking restitution of the property, payment of 120,000 PHP in back rent plus interest, and court costs.

Uploaded by

Kathleen Cruz
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

MUNICIPAL TRIAL COURT


Quezon City
Branch 00

RODEO JULIET
Plaintiff,

-versus- Civil Case No. 112


For: Unlawful Detainer

SPS. DELOS REYES


Defendant.
x- - - - - - - - - - - - - - - - - - - -/

COMPLAINT
PLAINTIFF, by counsel, and unto this Honorable Court, most
respectfully allege:

1. Plaintiff is of legal age, Filipino, with residence and postal address at B498,
Copernico St. San Isidro, Quezon City where he may be served notices
and other court processes;

2. Defendants are of legal age, Filipinos, with residence and postal address
at B498, Copernico St. San Isidro, Quezon City where they may be
served summons and other court processes;

3. Plaintiff is the absolute owner and lessor of that commercial space situated
at B498, Copernico St. San Isidro, Quezon City and now leased and
occupied by the Defendant;

4. The Defendant leases and occupies the said commercial space for their
small grocery business from March 1, 2019 until November 28, 2019 as
agreed upon between the plaintiff and the Defendant in the lease contract
executed on March 1, 2019 under the express obligation to pay a monthly
rental of P20,000.00; (Contract of Lease attached as Annex “A”)

5. The Defendant suffers economic losses due to the emergence of


convenience stores within the same area.

6. During the course of the Defendant’s occupation of the said commercial


space, Defendant has failed to pay their rentals for the months of June
2019 to November 2019;

7. Defendants has continued to occupy the said commercial space the


termination of their contract of lease on November 28, 2019 thus depriving
the plaintiff from having the said commercial space leased by other
persons;

8. Several demands to vacate was made by plaintiff to Defendants, both oral


and written (Demand letter attached as Annex “B”), but Defendant refused
to vacate the said townhouse and return possession to the plaintiff;
9. Until now Defendant still refuses to vacate and restore possession and pay
her rentals for the months June 2019 to November 2019 during their
occupation of the commercial space;

10. Thus, Defendant is unlawfully withholding possession of the subject


commercial space from the plaintiff despite last and final demand, to the
damage and prejudice of the plaintiff;

11. Before filing of this complaint, the dispute has been referred to the
Punong Barangay of Brgy. San Isidro, Quezon City but the parties failed to
arrive at an amicable settlement; (Certificate to File Action attached
as Annex “C”)

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of


this Honorable Court that after due notice and hearing, judgment be
rendered in favor of Plaintiff:

1. For the restitution of the abovementioned commercial space;

2. For the payment of ONE HUNDRED THOUSAND (PhP120,000.00)


PESOS, representing the arrears of rent now overdue and the interest
thereon;

3. To pay the costs for this suit.

Other reliefs just and equitable under the premises are likewise
prayed for.

Quezon City, Philippines, November 30, 2019.

Hospicio Legal Office


Counsel for Plaintiff
Unit 21, H Main Bldg. Lower Ground Floor EDSA Cor. North Avenue,
Bagong Pagasa, Quezon City

By:

Atty. Jonathan D. Segundo


Roll No.: 12345678
PTR No: 12345678
IBP No.: 12345678
MCLE Compliance No.: 12345678

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