COMPLAINT

Explorer vs. Belgas

Civil Case No. 61879

3
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
MUNICIPAL TRIAL COURT IN CITIES
San Carlos City, Pangasinan

TOM CRUISE,
Plaintiff,
- versus KATIE HOLMES,
Defendant.
x ----------------------------------x

Civil Case No. 61879

For: Ejectment

COMPLAINT
COMES NOW, the Plaintiff in the above entitled case, through counsel, and to this
Honorable Court alleges:
1.That plaintiff is of age, married and residing at No. 80 Agno Street, Quezon City,
while defendant is likewise of age, married and residing at No. 100 Agno Street, Quezon
City, where he may be served with summons;
2. That plaintiff is the owner of a semi-concrete bungalow located at No. 100 Agno
Street, Quezon City;
3.That on June 10, 2001, plaintiff leased the said bungalow to the defendant for the
next three (3) years at a monthly rental of P1,000.00, payable within the first five days of
each month, and that the lease contract thereon is hereto attached as Annex A;
4. That since June 11, 2004, the lease contract had already expired and, despite
repeated demands, defendant had refused to vacate the premises and continues to occupy
the same.
5. That written demand (Annex B hereof) to vacate and pay rentals in arrears was
sent to and received by defendant but despite said demand, he failed to vacate the same or
pay said rentals.
WHEREFORE, it is respectfully prayed that judgment be rendered against the defen
dant ordering her:
1. To vacate the premises;
2.To pay the monthly sum of P1,000.00 beginning on June 11, 2004, with interest
there on at the legal rate until fully paid, until the defendant vacates said premises;
3. To pay the sum of P2,000.00 as litigation expenses and attorneys fees.
Quezon City, July 7, 1983.

LAWRENCE VILLEGAS
Attorney for the Plaintiff
XYZ Building, Quezon City
IBP No. 12345; 1/3/1983; Quezon City
PTR No.61879; 2/2/1983; Quezon City
Roll of Attorneys No. 12344

COMPLAINT
Explorer vs. Belgas
Civil Case No. 61879

COMPLAINT
Nidora D. Explorer vs. Gusgus A. Belgas
Civil Case No. 98

REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION
MUNICIPAL TRIAL COURT IN CITIES
San Carlos City, Pangasinan
NIDORA D. EXPLORER,
Plaintiff,
- versus -

Civil Case No. 61879

GUSGUS A. BELGAS,
Defendant.

For: Unlawful Detainer

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

COMPLAINT
COMES NOW, the Plaintiff in the above entitled case, through counsel, and to
this Honorable Court alleges THAT:
1. The plaintiff is of age, married and residing at No.143 Brgy. Maharlika, San Carlos
City, while defendant is likewise of age, married and residing at No.44 Brgy.
Mayaman, San Carlos 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 Gen.
Luna St., San Carlos City, currently being leased and occupied by defendant;
3. The plaintiff, on June 10, 2012, leased the said building to the defendant for the
next three (3) years at a monthly rental of P20,000.00, payable within the first five
days of each month, and that the lease contract thereon is hereto attached as
Annex A;
4. That the defendant has failed to pay the rents for the months of January 2013 to
June 10, 2015, which now amounts to P600,000.00;
5. Since June 11, 2015, the lease contract had already expired and, despite repeated
demands, defendant had refused to vacate the premises and continues to occupy
the same.

COMPLAINT
Explorer vs. Belgas
Civil Case No. 61879

6. By reason of the unreasonable and wanton refusal of the defendant to vacate the
property of the plaintiff, the plaintiff was forced to litigate to enforce and protect his
property rights. As such the plaintiff incurred litigation expenses in the amount of
P12,000.00;
7. Without any legal justification, defendant continuously refuses to pay the said
amount despite repeated oral and written demands. A final letter was sent and
received personally by defendant on July 10, 2015, 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 B.

WHEREFORE, it is respectfully prayed that after due hearing, judgment be

rendered in favor of the plaintiff:
1. For the restitution of the abovementioned premises;
2. For the payment of P600,000.00, representing the arrears of rent now
overdue with legal interest from the filing of this complaint against
defendant;
3. For the defendant to pay P12,000.00 as litigation expenses and attorneys
fees.
Other reliefs just and equitable are likewise prayed for.
San Carlos City, July 30, 2015.

ATTY. MHELODY CRUZ

Counsel for the Plaintif
IBP No. 12345; 1/3/2000; Baguio City
PTR No.61879; 2/2/2000; Baguio City
Roll of Attorneys No. 459687
VERIFICATION & CERTIFICATION
OF NON FORUM-SHOPPING
_____________
I, NIDORA D. EXPLORER, of legal age, married, Filipino and a resident of
Barangay Maharlika, San Carlos City, Pangasinan, Philippines, after having been
sworn to in accordance with law, do hereby depose and state that:
1. I am the plaintiff in the above-stated case;

COMPLAINT
Explorer vs. Belgas
Civil Case No. 61879

2. That the facts stated in the above complaint are true and correct to the best
of my knowledge and authentic records;
3. I have not commenced any action or filed any claim involving the same issues
in any court, tribunal or quasi-judicial agency and, to the best of my
knowledge, no such other action or claim is pending in them; and
4. If I should learn that the same or similar axction or claim has been filed or is
pending after its filing, I shall report that fact within fice (5) days from notice
to the court or where the complaint or initiatory pleading has been filed.
IN WITNESS WHEREOF, I hereunto affixed my signature this 30 th day of July
30, 2015 at San Carlos City, Pangasinan, Philippines.
NIDORA D. EXPLORER
Affiant

SUBSCRIBED AND SWORN to before me, this 30th day of July, 2015, in the City
of San Carlos, Pangasinan, by Nidora D. Explorer with Passport No. 21345XV7-13
issued on January 2015 at San Fernando City, La Union.

Doc. No. ______;

Page No.______;
Book No. _____;
Series of _____.

Atty. PIA N. ONO

Notary Public
Commission Serial No.____
Until December 31, 2016
IBP No. 12345; 1/3/1983; Quezon City
PTR No.61879; 2/2/1983; Quezon City
Roll of Attorneys No. 12344