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Unlawful Detainer Complaint Template

1. The plaintiff filed a complaint for unlawful detainer against the defendant for failing to vacate and pay rent for a townhouse. 2. The defendant leased the townhouse from March 2012 to February 2017 but failed to pay rent from June 2016 to February 2017 after the lease expired. 3. Despite demands, the defendant continues to occupy the townhouse without permission, depriving the plaintiff of income. The plaintiff is seeking restitution of the property, unpaid rent of 180,000 pesos, and court costs.

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477 views3 pages

Unlawful Detainer Complaint Template

1. The plaintiff filed a complaint for unlawful detainer against the defendant for failing to vacate and pay rent for a townhouse. 2. The defendant leased the townhouse from March 2012 to February 2017 but failed to pay rent from June 2016 to February 2017 after the lease expired. 3. Despite demands, the defendant continues to occupy the townhouse without permission, depriving the plaintiff of income. The plaintiff is seeking restitution of the property, unpaid rent of 180,000 pesos, and court costs.

Uploaded by

milleran
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
  • Complaint Introduction: Introduces the complaint document with details of the plaintiff, defendant, and general context of the legal action.
  • Complaint Details: Describes the legal reasonings, contractual obligations, and potential breaches alleged against the defendant.
  • Further Allegations: Continues with additional allegations and legal points reinforcing the plaintiff's stance in the case.
  • Prayer for Relief: Concludes the legal document with specific demands for judgment and compensation sought by the plaintiff.
  • Legal Formalities: Contains formal legal language regarding legal certifications, the legal team, and document attachments.

Republic of the Philippines

MUNICIPAL TRIAL COURT (IN CITIES)


(Name of City / Municipality)

(NAME OF PLAINTIFF)
Plaintiff,

              -versus- Civil Case No. ______


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

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