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Republic of the Philippines )

Tuguegarao City, Cagayan ) s.s.

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Respectfully alleges:

I, LAUREAN ANNE B. SANTOS, of legal age, single and a resident of Tabuk City,
Kalinga, after having been duly sworn in accordance with law, hereby depose and state
1. I am a tenant of LUCIANA “Luz” TALLUD since 2013, with the address Rose
st., San Gabriel, Tuguegarao City, paying eight hundred pesos (₱800.00) on a
monthly-basis, without receiving any receipt since then.
2. That the boarding house business of Mrs. Tallud is committing non-compliance
to the law, specifically against Republic Act No. 8424, pertaining the registration
of the said business property, non-issuance of official receipts and tax evasion.
The non-conformity is evidenced by my prior complaint to the BIR, in which
they validly merited, marked as annex “A”.
3. That I have a balance of nine hundred pesos (₱900.00) pertaining to my
monthly due for the month of October.
4. That on November 21, 2017, Mrs. Tallud clamored outside my room, hinting
about her intent to eject me as her tenant by shrieking the words “humanap na
kayo ng ibang boarding! Hindi naman kayo nagbabayad! May mga bayarin sa
bills! Hindi yun libre!”
5. That on November 25, 2017, I went home to our house in Tabuk then came
back the next day, November 26, 2017 and was stunned when I saw all of my
belongings, notably outside and far from my room. This appeared to me as
constructive ejection already and had been my driving force to vacate the
property, taking with me my two (2) bags but leaving behind an electric fan, an
iron, two (2) more bags and my durabox containing almost all of my clothes.
6. That on November 26, 2017, I went back to my rented room but to my
astonishment, all of my property that I left were gone except the two (2) bags
containing only rubbish and dirtied clothes. Later in the afternoon, Mrs. Tallud
texted me that she will keep all of my property until she gets paid therefore
depriving me of my property, violating my right as stated in ARTICLE III, Section
I of the Constitution.
7. That since the incident the respondent has been charging me, two thousand
one hundred fifty (₱2150.00), with a breakdown of:
900.00………………………Unpaid balance
800.00………………………Monthly due for October
8. That I do not have any knowledge to the damaged doorknob she was charging
me, because since the beginning of my stay in that room, the doorknob was
already damaged and no key had been turned over to me. The monthly charge
is also deemed unjust considering the breaches of lease agreement that she
committed, e.g. two (2) weeks of no electricity due to their negligence in paying
the electricity bill and the date of taking my possession.
9. That by reason of the foregoing, I had been experiencing sleepless nights
brooding on where to stay the next day, facing problems concerning lack of
clothing and peer embarrassment due to Mrs. Tallud’s taking, without due
process, my belonging which, I believe, that the latter should compensate.
10. That I am executing this affidavit to attest the truth of the foregoing averments
and for the purpose of filing an action for replevin and applying for civil damages
against said LUCIANA “LUZ” TALLUD as she illegally took possession of my
properties, specifically one (1) electric fan, one (1) iron, and durabox containing
almost all of my clothes ONLY by reason of payment enforcement.

IN WITNESS WHEREOF, I have affixed my signature this 1st day of December

2017 in Tuguegarao City, Philippines.