Republic of the Philippines

Municipal Trial Court

Branch 8
Iloilo City

MA. SHIRLEY S. BERIONES, Plaintiff CIVIL CASE NO. 381978

FOR: Unlawful Detainer
-versus-

RHODERICK S. NIETES, Defendant

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

COMPLAINT

COMES NOW, the plaintiff together with the undersigned counsel to this most honorable
court, MOST RESPECTFULLY STATES THAT;

1. The Plaintiff is of legal age, married, and a resident of Muyco St. Dingle, Iloilo. The
Defendant is likewise of legal age, single, and temporary residing at Corner 10th and
11th Street, Phase 1, Alta Tierra Village, Jaro, Iloilo City;

2. The Plaintiff is the owner of the house and lot located at the Corner 10th and 11th
Street, Phase 1, Alta Tierra Village, Jaro, Iloilo City, as evidenced by pertinent
documents like the tax declaration, deed of sale, and transfer certificate of title.
(EXHIBIT A );

3. The Defendant is the lessee of the property that is owned by the Plaintiff as
evidenced by the written contract of lease that both parties signed. (Exhibit B);

4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid
property for a consideration of TEN THOUSAND PESOS (Php 10,000.00) a month as
rental to be paid within the first ten (10) days of each month starting July 2010;

5. That both parties have agreed upon Item No. 15 of the said contract explicitly
provides an interest rate of 2% per month shall be imposed as penalty on unpaid
rentals;

6. The defendant failed to pay the agreed rental for several months starting February
19, 2012 up to the present;

7. On January 1, 2017 the plaintiff sent a letter of demand to vacate the apartment
which was received by the defendant as shown in the registry return receipt hereto
attached as Annex A;

8. Despite said letter of demand which was repeated by oral demands, the defendant
failed and still refused to pay the agreed amount of rentals and to vacate the
property;

9. By reason of failure of the defendant to vacate the premises and to pay the unpaid
rentals, the plaintiff was compelled to file this complaint engaging the services of
counsel in the amount of THIRTY THOUSAND PESOS (Php 30,000).
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable

Court that, after hearing, judgment be rendered ordering the defendant:

1. To vacate the subject premises;

2. To pay the amount of TEN THOUSAND PESOS (Php 10,000.00) per month as
compensation for the reasonable use of the subject premises and the agreed upon
interest for the unpaid amounts of rent due, until they finally vacate the said premises;

3. To pay the plaintiff the cost of the suit;

City of Iloilo, May 5, 2017.

Atty. Juan Dela Cruz

Counsel for the Plaintiff
PTR No. 1234567, Iloilo City, 1/2/17
IBP OR No. 654321, Iloilo City, 1/2/17
Attorneys Roll No. 11223
MCLE Compliance Certificate No. IV-0012345, Iloilo City, 1/2/17

VERIFICATION AND CERTIFICATION

I, Ma. Shirley S. Beriones, of Legal age, married, Filipino Citizen and a resident of Muyco St,
Dingle, Iloilo, after being sworn according to law, hereby depose and state that;

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and correct of my
personal knowledge and/or on the basis of copies of documents and records in my
possession;

4. I have not commenced any other action or proceeding involving the same issues in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or proceeding is pending in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to this Honorable
Court.

Ma. Shirley Beriones

Plaintiff
SUBSCRIBED AND SWORN to before me, this 20th day of April 2017 in Iloilo City, with
affiant exhibiting her Drivers License with I.D. No. 12345 issued by the Land Transportation
Office on May 5, 2017 at the City of Iloilo.

Atty. Juan Dela Cruz

NOTARY PUBLIC
PTR No. 1234567, Iloilo City, 1/2/17
IBP OR No. 654321, Iloilo City, 1/2/17
Attorneys Roll No. 11223
MCLE Compliance Certificate No. IV-0012345, Iloilo City, 1/2/17

Doc. No. : ________;

Page No. : ________;
Book No. : ________;
Series of 20_________.