REPUBLIC OF THE PHILIPPINESREGIONAL TRIAL COURTCity of TACLOBANBranch 19LADY GAGA, Plaintiff, CIVIL CASE No. 143143 -versus- FOR: Unlawful Detainer MILEY CYRUS, Defendant.x-----------------------------------x
COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel and unto this HonorableCourt, most respectfully avers:1.That the plaintiff, LADY GAGA, is of legal age, Filipino citizen, single, with residenceand postal address at blk 4, lot 9, Happy Homes, Diit, Tac. City;2.That the defendant, MILEY CYRUS, is of legal age, Filipino citizen, single, withresidence and postal address at Phase 5, V&G, Tac. City, where they may be served withsummons and other court processes;3.The plaintiff is the owner of a land over which a boarding house had been constructedlocated in Del Pilar St., Tacloban City;4.By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid boarding house for a consideration of P9,000 a month as rental to be paid within the firstten (15) days of each month starting December 30, 2020;5.The defendant failed to pay the agreed rental for several months starting June 30, 2021 upto the present;6.On August 9, 2021, the plaintiff sent a letter of demand to vacate the boarding housewhich was received by the defendant as shown in the registry return receipt heretoattached as Annex “A”;7.Despite said letter of demand which was repeated by oral demands, the defendant failedand still refused to pay the agreed amount of rentals and to vacated the apartment;8.By reason of failure of the defendant to vacate the premises and to pay the unpaid rentals,the plaintiff was compelled to file this complaint engaging the services of counsel in theamount of P15,000.00. WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that, after hearing, judgment be rendered ordering the defendant:
1.To vacate the subject premises;2.To pay the amount of P9,000.00 per month as compensation for the reasonable use of thesubject premises until they finally vacate the said premises;3.To pay the plaintiff the cost of the suit amounting to P15,000 City of Tacloban, September 28, 2021. MA. GORETTI GULA-GARCIA LAW & NOTRAY OFFICE Counsel for the Plaintiff Door 7, Cabigon Building, Del Pilar St., Tacloban City By: Ma. Goretti Gula-Garcia Roll of Attorney No. 12345 IBP No. 12345/1-2-34/Tacloban PTR No. 67891/5-67-89/Tacloban
VERIFICATION/CERTIFICATION OF FORUM SHOPPING
Republic of the Philippines )City of Tacloban ) S.S. I, LADY GAGA, of legal age, Filipino citizen, single and resident of Blk 4, Lot 9, HappyHomes, Diit, Tac. City, after having been duly sworn to in accordance with law do herebydepose and say:1.That I am the plaintiff in the above-entitled case;2.That I have caused the preparation of the foregoing complaint and have read theallegations contained therein;3.The allegations in the said complaint are true and correct of my own knowledge andauthentic records;4.I hereby certify that I have not commenced any other action or proceeding involving thesame issues in any court, tribunal or quasi-judicial agency and, to the best of myknowledge, no such other action or claim is pending therein;5.That if I should learn thereafter that a similar action or proceeding has been filed or is pending, I hereby undertake to report that fact within five (5) days therefrom to the courtor agency where the original pleading and sworn certification contemplated herein have been filed;6.I executed this verification/certification to attest to the truth of the foregoing facts and tocomply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court. IN WITNESS WHEREOF, I have hereunto affixed my signature this 28th of September 2021, in the City of Tacloban. LADY GAGA
SUBSCRIBED AND SWORN to before me this 28
th
day of September, 2021, in the City of Tacloabn, affiant exhibiting to me his Driver’s License No. H02-12-123456 issued by the Land Transportation Office on July 4, 2018 at the City of Tacloban . ATTY. NO CASE Notary Public My Commission Expires Dec. 31, 2023 Roll of Attorney No. 12345 IBP No. 12345/1-2-34/Tacloban PTR No. 67891/5-67-89/TaclobanDoc. No. ________ Page No. _______ Book No. _______ Series of 2021
Republic of the Philippines
Municipal Trial Court
Branch 5Baguio City
Mr. Uzumaki Naruto, plaintiff Civil Case No. 2Accompanied by his
Attorney –in – fact,
for:Unlawful DetainerAtty. Poging Attorney -versus-Mr. Uchiha Sasuke, Defendantx-----------------------------------------x
COMPLAINT
COMES NOW, the plaintiff together with the undersigned counsel to this mosthonorable court, MOST RESPECTFULLY STATES THAT;
1.
The Plaintiff is of legal age, married and a resident of Puguis, La Trinidad Benguet. TheDefendant is likewise of legal age, married and temporary residing at Petersville Subdivision,Baguio City.2.
The Plaintiff is the owner of the two-storey house unit located at the Petersville Subdivision,Baguio City, and having the residential address of PV 123 as evidenced by pertinent documentslike tax declaration and deed of sale. ( EXHIBIT “A” )3.
The Defendant is the lessee of the house unit that is owned by the Plaintiff as evidenced by thewritten contract of lease that both parties signed. (Exhibit “B”)4.
The Plaintiff and the Defendant came up with a written agreement of Lease on June 26, 2007,which they both agreed upon and was duly signed by the two parties as shown in their contract of lease. (Exhibit “B”)5.
Item No. 16 of the contract which the defendant signed expressly provides that he will only beoccupying the property for one (1) year, after which, he will vacate the house when that termexpires. (Exhibit “B”)6.
The contract also provides that the defendant should also take care of the property and its premises” with the utmost diligence”.7.
On June 28, 2008, the plaintiff, after returning from Japan, was surprised to discover that thedefendant did not vacate the property as he expected. Worse, he installed a “sari-sari store” in theoriginal building structure of the house unit.8.
The plaintiff confronted the defendant about it but the defendant claimed that it was a “DEEDOF SALE” which they signed and not a “CONTRACT OF LEASE” and therefore, the defendantis the new owner of the house unit.