Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Branch ____
Iloilo City

REYNOLD G. TANZA,
Plaintiff,
Civil Case No. _____
-versus- FOR: Unlawful Detainer

ARDIE JAY F. DAVIDE,

Defendant.
x-------------------------------x

COMPLAINT

PLAINTIFF, through the undersigned counsel and unto this Honorable

Court, most respectfully states:

1. That the plaintiff, REYNOLD G. TANZA, is of legal age, Filipino

citizen, single, resident of 156 Brgy. Sambag, Jaro, Iloilo City, and the
defendant, ARDIE JAY F. DAVIDE, is of legal age, Filipino citizen,
single, resident of Brgy. Poblacion, Sebaste, Antique, where they may
be served with summons and other court processes;

2. That the plaintiff is the owner of a 200 square-meter lot over which an
apartment had been constructed located at 123 Cruz St., La Paz, Iloilo
City;

3. That on April 30, 2011, the plaintiff entered into a written contract with
defendant whereby the former leased to the latter the above described
property for the period of three (3) years, starting on August 1, 2011,
for the monthly rental of Twenty Thousand Pesos (P20,000), copy of
which contract of lease is attached hereto as Annex “A”;

4. That by virtue of the said contract, Annex “A”, defendant took

possession of the property in question on August 3, 2010, and he is still
in possession of the same up to the present time;

5. That the period stipulated in the contract, Annex “A”, has already
expired last August 3, 2014;

6. That despite repeated demands, defendant still refused to vacate the

subject property. A copy of the final demand sent to defendant is herein
attached as Annex “B”;
 7. That as a consequence of defendant’s refusal to vacate plaintiff’s
property, the plaintiff was compelled to file this complaint engaging the
services of counsel in the amount of PhP 30,000.00.

PRAYER

WHEREFORE, plaintiff most respectfully prays unto this Honorable

Court that, after due hearing, judgment be rendered in his favor ordering the
defendant to vacate the premises and to return the possession thereof to
plaintiff plus costs.

Other reliefs which are just and proper under the premises are likewise
prayed for.

Iloilo, Philippines, March 20, 2015.

ATTY. VINCENT ENRIQUE A. VARONA

Counsel for the Plaintiff
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876, 01/02/14
Republic of the Philippines )
City of Iloilo )S.S.
x---------------------------------------x

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING

I, REYNOLD G. TANZA, of legal age, single, Filipino and resident

of 156 Brgy. Sambag, Jaro, Iloilo City, Philippines after having been duly
sworn in accordance with the law, hereby depose and say:

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

2. That, I have caused the application of the foregoing pleading;

3. That, 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. That 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. That 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. That 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.

IN WITNESS WHEREOF, I hereunto set my hand this 20th day of

March, 2015 at Iloilo, Philippines.

REYNOLD G. TANZA
Affiant
Driver’s License No.: F01-118-897
Valid until: December 30, 2015
 SUBSCRIBED AND SWORN TO before me this 20th day of March,
2015 at Iloilo, Philippines, affiant having exhibited to me his Driver’s License
as above stated as competent evidence of identity.

ATTY. VINCENT ENRIQUE A. VARONA

Notary Public for and in the City and Province of Iloilo
My Commission No. is 58
Expires on December 31, 2015
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876, 01/02/14

Doc. No. 8;
Page No. 3;
Book No. 1;
Series of 2015.