Republic of the Philippines

MUNICIPAL TRIAL COURT

Quezon City

EVA CARINO BRUTAL

Plaintiff,

              -versus- Civil Case No. ______

For: Unlawful Detainer

MR. ANDREW F. MEDINA and

Bobby De la Cruz
Defendant.
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COMPLAINT

          Complainant, by counsel, and unto this Honorable Court, most

respectfully alleges: -THAT-

PARTIES

1. Complainant is of legal age, Filipino, single/married with residence and

postal address at #69 Hobart St., ABC Homes, Las Pinas City, where
she may be served with summons and other court processes;

2. Defendant, Andrew Medina, is of legal age, Filipino, single, with

residence and postal address at 134 Kaunlaran Street Barangay
Commonwealth, Quezon City where he may be served with notices and
other court processes;

3. Defendant, Bobby De la Cruz, is of legal age, Filipino, single, with

residence and postal address at 456 Casa Pura, Barangay Culiat,
Quezon City where he may be served with notices and other court
processes;

ALLEGATIONS IN SUPPORT OF THE CAUSE OF ACTION

4. Bobby De La Cruz, sold the subject property with the knowledge that
the lessee has the right of first refusal.

5. ANDREW F. MEDINA, bought the subject property with the knowledge

that a lessee is still leasing the property

6. Defendant ANDREW F. MEDINA, violated Section 9 of R.A. 9653 for

failing to state a valid ground for the ejection of the lessee and failing
to give sufficient notice to the lessee before ejecting the latter.

7. That the Defendant ANDREW F. MEDINA violated Section 10 of R.A.

9653 which states that no lessor or his successor-in-interest shall be
entitled to eject the lessee upon the ground that the leased premises
 have been sold or mortgaged to a third person regardless of whether
the lease or mortgage is registered or not.

8. Defendant committed grave coercion by ordering the security guards

of the subdivision that the plaintiff is not allowed to leave the premises
without paying the rent

PRAYER

          WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that after due notice and hearing, judgment be
rendered in favor of Plaintiff:

1. To enjoin the defendant to rescind the deed of sale and that the
owner sell the property to the defendant.

2. To dismiss the complaint of Unlawful Detainer against the defendant.

3. To make Defendant ANDREW F. MEDINA, liable for grave coercion

4. To pay the costs for this suit and damages.

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

Quezon City, Philippines, January 13, 2021

CAS LAW OFFICE

Counsel for Plaintiff
No. 24, 12th Ave., Cubao,
Quezon City

By:

Shane Yrah Cas

Roll No.: 65212
PTR No: 0327314;1-2-2020: QC
IBP No.: 0932928/01-09-2020: QC
MCLE Compliance No.: V-0009942
/07-01-2020

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, EVA CARINO BRUTAL, of legal age, Filipino, and a resident of #69 Hobart
St., ABC Homes, Las Pinas City, Single, on oath, states:
1. That I as the plaintiff in the above-entitled case have caused this
Complaint to be prepared; that I read and understood its contents which are
true and correct of my own personal knowledge and/or based on true
records;
2. That I have not commenced any action or proceeding involving the
same issue and specifically the same check/s in the Supreme Court, the
Court of Appeals or any other tribunal or agency, particularly before the
Office of the City Prosecutor of Quezon City; that to the best of my
knowledge, no such action or proceeding is pending in the Supreme Court,
the Court of Appeals or any other tribunal or agency, and that, if I should
learn thereafter that a similar action or proceeding has been filed or is
pending before these courts or tribunal or agency, I undertake to report that
fact to the Court within five (5) days therefrom.

IN WITNESS WHEREOF, I have hereunto set my hand this 23rd day

of January, 2021.

_____________________________
Affiant

SUBSCRIBED AND SWORN to before me this 23 day of January, 2021.

NOTARY PUBLIC