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(NAME OF PLAINTIFF)
Plaintiff,
(NAME OF DEFENDANT),
Defendant.
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COMPLAINT
PLAINTIFF, by counsel, and unto this Honorable Court, most
respectfully allege: -THAT-
3. Plaintiff is the absolute owner and lessor of that certain townhouse situated
at (Location of property) and now leased and occupied by the Defendant;
4. The Defendant leases and occupies the said townhouse from March 1, 2012
until February 28, 2017 as agreed upon between the plaintiff and the
Defendant in the lease contract executed on March 1, 2012 under the
express obligation to pay a monthly rental of P20,000.00; (Contract of Lease
attached as Annex “A”)
5. The lease contract of the Defendant for the occupation of the building has
been terminated on February 28, 2017 and has not been renewed or
extended;
8. Several demands to vacate was made by plaintiff to Defendant, both oral and
written(Demand letter attached as Annex “B”), but Defendant refused to
vacate the said townhouse and return possession to the plaintiff;
9. Until now Defendant still refuses to vacate and restore possession and pay
her rentals for the months June 2016 to February 2017 during her occupation
of the townhouse;
11. Before filing of this complaint, the dispute has been referred to the Lupong
Tagamayapa of (Name of City or Municipality) but the parties failed to
arrive at an amicable settlement; (Certificate to File Action attached
as Annex “C”)
PRAYER
Other reliefs just and equitable under the premises are likewise prayed
for.
By:
(NAME OF LAWYER)
Roll No.: ____________
PTR No: ____________
IBP No.: ____________
MCLE Compliance No.: ____________
ATTACH: