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Unlawful Detainer Complaint in Manila

Martin Quezon filed a complaint for unlawful detainer against Juan de la Cruz. Quezon owns a building that de la Cruz leases and occupies, with an obligation to pay 20,000 PHP monthly rent within the first 5 days of each month. De la Cruz failed to pay rent for November and December, totaling 40,000 PHP in arrears. Despite demands, de la Cruz refuses to pay. Quezon prays for restitution of the premises and payment of the 40,000 PHP arrears plus interest and costs.

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62 views2 pages

Unlawful Detainer Complaint in Manila

Martin Quezon filed a complaint for unlawful detainer against Juan de la Cruz. Quezon owns a building that de la Cruz leases and occupies, with an obligation to pay 20,000 PHP monthly rent within the first 5 days of each month. De la Cruz failed to pay rent for November and December, totaling 40,000 PHP in arrears. Despite demands, de la Cruz refuses to pay. Quezon prays for restitution of the premises and payment of the 40,000 PHP arrears plus interest and costs.

Uploaded by

kitakattt
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Republic of the Philippines

Regional Trial Court


Manila

Martin Quezon
Plaintiff-Appellant,

G.R. No. 768990


– versus –

FOR: Complaint for Unlawful Detainer

Juan de la Cruz
Defendant-Appellee,

x-----------------x

COMPLAINT

Plaintiff, thru counsel, respectfully avers that:

1. The plaintiff is of age and a resident of 1030 A Craig St., Sampaloc, Manila while the
defendant is also of age, with residence at 123 Narra St., Fairville Quezon, City.
Where he may be served with summons and other court processes;

2. The plaintiff is the absolute owner and lessor of a certain building located at 752
Montana St., Sampaloc, Manila, currently being leased and occupied by the
defendant;

3. The defendant leases and occupies the said building under the express obligation of
paying a monthly rent of twenty thousand pesos (Php 20,000.00) Payable within the
first five (5) days of each month.

4. The defendant has failed to pay the rents for the months of November, December,
which amounts to forty thousand pesos (Php 40, 000.00);

5. Without any legal justification, defendant continuously refuses to pay the said amount
despite repeated oral and written demands. A final demand letter was sent and
received personally by defendant on January 2, 2018, or more than five (5) days
before the filing of this complaint. A copy of the final demand letter to pay the arrears
and to vacate the premises is here attached as Annex “A.”
WHEREFORE, it is respectfully prayed that after due hearing, judgement be rendered in
favor of the plaintiff:

a. For the restitution of the abovementioned premises; and


b. For the payment of Php 40, 000.00, representing the arrears of rent now overdue, with
legal interest from the filing of this complaint, and costs of suit.

Other reliefs just and equitable are likewise prayed for.

Manila; January 18, 2018.

(Sgd.) BACANI and ASSOCIATES


Counsel for the Plaintiff
(Address)

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