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Lukresia Pataykangbataka,
Plaintiff,
CIVIL CASE No. 11111
-versus- FOR: Unlawful Detainer
Marlene Dietrich,
Defendant.
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COMPLAINT
COMES NOW, the plaintiff through the undersigned counsel and unto this
Honorable Court, most respectfully avers:
The Parties
1. That the plaintiff is a Filipino citizen, of legal age, single, with
residence and postal address at Purok 4, Brgy. Andres Bonifacio,
Diffun, Quirino;
2. That defendant is also a Filipino citizen, of legal age, married, with
residence and postal address at No. 456, Brgy. Marupok, Cauayan City,
Isabela, where she may be served with summons and other court
processes;
The Facts
3. The plaintiff is the owner of a land over which an apartment has been
constructed located at Brgy. Sinsayon, Santiago City, Isabela;
4. By virtue of a Contract of Lease, plaintiff leased unto defendant the
aforesaid apartment for a consideration of SEVEN THOUSAND
(P7,000.00) PESOS a month as rental to be paid within the first
FIFTEEN (15) days of each month starting February 2018. A copy of
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the contract is attached as ANNEX “A” and made an integral part of
this complaint;
5. The defendant failed to pay the agreed rental for several months starting
July 15, 2018 up to the present;
6. On November 3, 2018, the plaintiff sent a letter of demand to vacate the
apartment which was received by the defendant. A copy of the
plaintiff’s letter to defendant is attached as ANNEX “B” and made
integral part of this complaint;
7. Despite said letter of demand which was repeated by oral demands,
defendant has refused to vacate the premises and continues to occupy
the property;
8. By reason of failure of the defendant to vacate the premise and pay the
unpaid rentals, the plaintiff was compelled to file his complaint
engaging the services of counsel in the amount of TWENTY
THOUSAND (P20,000.00) PESOS.
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5th Floor, Dimahanapan Building
Malvar, Santiago City
IBP No. 123458/12-12-19/Santiago City
PTR No. 987654/ 12-22-19/Santiago City
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Lukresia Pataykangbataka
Affiant