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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


2nd Judicial Region
Branch 36
Santiago City

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.

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 SEVEN THOUSAND (P7,000.00) PESOS per
month as compensation for the reasonable use of the subject premises
until she finally vacates the said premise; and
3. To pay the plaintiff the cost of this suit.

City of Santiago, February 25, 2019.

Atty. Lurimar A. Raguini


Counsel for the Plaintiff
Roll of Attorney No. 230219

2
5th Floor, Dimahanapan Building
Malvar, Santiago City
IBP No. 123458/12-12-19/Santiago City
PTR No. 987654/ 12-22-19/Santiago City

VERIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines )


City of Santiago ) S.C.

I Lukresia Pataykangbataka, of legal age, Filipino citizen, married


and resident of Purok 4, Brgy. Andres Bonifacio, Diffun, Quirino, after having
been duly sworn to in accordance with the law do hereby depose and say:
1. That I am the plaintiff in the above-titled case;
2. That I have caused the preparation of the foregoing complaint and have
read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic record;
4. That I have not commenced any other action or proceeding involving
the same issues in the Supreme Court, Court of Appeals, or any other
tribunal or agency;
5. That if I should thereafter learn that a similar action or proceeding has
been filed or is pending, I hereby undertake to report the fact within
five (5) days therefrom to the court or agency where the original
pleading and sworn certification contemplated herein have been filed;
6. That I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular No.
04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 25th


of February 2019, in Santiago City.

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Lukresia Pataykangbataka
Affiant

SUBSCRIBED AND SWORN to before me this 25th day of February,


2019, in Santiago City, affiant exhibiting to me her Driver’s License No.
123456 issued by the Land Transportation Office on April 27, 2017 at
Santiago City.

Atty. Lurimar A. Raguini


Roll of Attorney No. 230219
5th Floor, Dimahanapan Building
Malvar, Santiago City
IBP No. 123458/12-12-19/Santiago City
PTR No. 987654/ 12-22-19/Santiago City

Doc. No. ______


Page No. ______
Book No.______
Seried of 2019.