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ALYSSA CANA,
Plaintiff
CIVIL CASE No. 9889
-versus- FOR: Unlawful Detainer
AYO KHO,
Defendant.
x---------------------------------x
COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel
and unto this Honorable Court, most respectfully avers:
1. That the plaintiff, ALYSSA CANA, is of legal age, Filipino citizen,
single, with residence of Block 1, Lot 3, Lumbang 2 Subdivision, Brgy.
96 Calanipawan, Tacloban City;
2. That the defendant, AYO KHO, is of legal age, Filipino citizen, single,
with residence and postal address at Phase 5, Block 5, Lot 5, Lauaan
Street, V&G Subdivision, Tacloban City, where they may be served
with summons and other court processes;
3. That the plaintiff is the owner of a land over which an apartment had
been constructed located Phase 3, Block 3, Lot 16, Chico Street,
V&G Subdivision, Tacloban City;
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6. That the defendant failed to pay the agreed rental for several months
starting August 23, 2017 up to the present;
7. That on October 25, 2017 the plaintiff sent a letter of demand to
vacate the apartment which was received by the defendant as shown
in the registry return receipt hereto attached as Annex “A”;
8. That a final letter of demand to vacate and pay rentals was sent on
November 25, 2017 which was received by the defendant as shown
in the registry return receipt as Annex “B”;
10. That the plaintiff filed a complaint to the Office of Tagapamayapa but
efforts of the latter proved futile as the defendant adamantly refused
to vacate the premises, constraining the Lupon Tagapamayapa to
issue a certificate to file the instant complaint copy of which certificate
is attached hereto as Annex “C”;
By:
Atty. Antonio Primo Arellano
Roll of Attorney No. 98765
IBP No. 12345/2-5-17/Tacloban
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PTR No. 87654/12-22-17/Tacloban
MCLE No. 12345
VERIFICATION/CERTIFICATION OF FORUM SHOPPING
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
ALYSSA CANA
JURAT
SUBSCRIBED AND SWORN to before me, this 19th February
2018, by ALYSSA CANA who exhibited to me her Driver’s License
No. 12345096865346 issued by the Land Transportation Office on
April 8, 2012 at the City of Tacloban.
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