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Municipal Trial Court (In Cities) (Name of City / Municipality)

This complaint was filed by a plaintiff landlord against a defendant tenant in municipal trial court. It alleges that the defendant leased a townhouse from the plaintiff from 2012 to 2017, but failed to pay rent from June 2016 to February 2017. It also claims the defendant continues occupying the property despite the lease ending, depriving the plaintiff of renting to others. The plaintiff demands restitution of the property, payment of 180,000 pesos in back rent, and court costs.

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Ray Mos
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111 views3 pages

Municipal Trial Court (In Cities) (Name of City / Municipality)

This complaint was filed by a plaintiff landlord against a defendant tenant in municipal trial court. It alleges that the defendant leased a townhouse from the plaintiff from 2012 to 2017, but failed to pay rent from June 2016 to February 2017. It also claims the defendant continues occupying the property despite the lease ending, depriving the plaintiff of renting to others. The plaintiff demands restitution of the property, payment of 180,000 pesos in back rent, and court costs.

Uploaded by

Ray Mos
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

Republic of the Philippines

MUNICIPAL TRIAL COURT (IN CITIES)


(Name of City / Municipality)

(NAME OF PLAINTIFF)
Plaintiff,
Civil Case No. ______
-versus- For: Unlawful Detainer

(NAME OF DEFENDANT),
Defendant.
x- - - - - - - - - - - - - - - - - - - -/

COMPLAINT
PLAINTIFF, by counsel, and unto this Honorable Court, most
respectfully allege: -THAT-
1. Plaintiff is of legal age, Filipino, with residence and postal address
at (Residential address of plaintiff) where he may be served
notices and other court processes;
2. Defendant is of legal age, Filipino, with residence and postal address
at (Residential address of defendant), where he may be served
summons and other court processes;
3. Plaintiff is the absolute owner and lessor of that certain townhouse
situated at (Location of property) and now leased and occupied by
the Defendant;

4. The Defendant leases and occupies the said townhouse from March
1, 2012 until February 28, 2017 as agreed upon between the plaintiff
and the Defendant in the lease contract executed on March 1, 2012
under the express obligation to pay a monthly rental of
P20,000.00; (Contract of Lease attached as Annex “A”)
5. The lease contract of the Defendant for the occupation of the building
has been terminated on February 28, 2017 and has not been
renewed or extended;

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


townhouse, Defendant has failed to pay his rentals for the months of
June 2016 to February 2017;
7. Defendant has continued to occupy the said townhouse
notwithstanding the fact that her contract of lease has been
terminated on February 28, 2017 thus depriving the plaintiff from
having the said townhouse leased by other persons;
8. Several demands to vacate was made by plaintiff to Defendant, 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 2016 to February 2017
during her occupation of the townhouse;
10. Thus, Defendant is unlawfully withholding possession of the subject
townhouse 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
Lupong Tagamayapa of (Name of City or Municipality) 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 townhouse;
2. For the payment of ONE HUNDRED THOUSAND (PhP180,000.00)
PESOS, representing the arrears of rent now overdue;
3. To pay the costs for this suit.

Other reliefs just and equitable under the premises are likewise
prayed for.
(Place of Filing), Philippines, (Date of Filing).

(NAME OF LAW OFFICE)


Counsel for Plaintiff
(Address of law office)

By:
(NAME OF LAWYER)
Roll No.: ____________
PTR No: ____________
IBP No.: ____________
MCLE Compliance No.: ____________

ATTACH:
Verification and Certification of Non-forum Shopping
Annexes

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