REPUBLIC OF THE
PHILIPPINES
METROPOLITAN TRIAL COURT
City of Iloilo
Branch 23
STEVEN JOHNSON
Plaintiff.
-versus- CIVIL CASE NO. C-123456-89
For: Unlawful Detainer
MICHAEL GOETTER
Defendant.
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COMPLAINT
The plaintiff, through the undersigned counsel and to this Honorable
Court, respectfully avers:
1. That plaintiff, Steven Johnson, is of legal age, Filipino citizen, single,
with residence and postal address at Lopez Jaena St., Jaro , Iloilo City;
2. That defendant is Michael Goetter, of legal age, Filipino citizen, single,
with residence and postal address at at Tabuc Suba, Jaro, Iloilo City,
where he may be served with summons and other Court processes;
3. The plaintiff is the owner of a land over which an apartment had been
constructed located 143 San Juan Street, Iloilo City
4. By virtue of a contract of lease, the plaintiff leased unto the defendant the
aforesaid apartment for a consideration of P5,000.00 a month as rental to
be paid within the first ten (10) days of each month starting January 3,
2015;
5. The defendant failed to pay the agreed rental for several months starting
September 19, 2015 up to the present;
6. On November 3, 2015, 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”;
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7. Despite said letter of demand which was repeated by oral demands, the
defendant failed and still refused to pay the agreed amount of rentals and
to vacate 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 the amount of P20,000.00.
WHEREFORE, premises considered, it is most respectfully prayed unto
this Honorable Court that, after hearing, judgment be rendered ordering
the defendant:
a. To vacate the subject premises;
b. To pay the amount of P5,000.00 per month as compensation for the
reasonable use of the subject premises until they finally vacate the said
premises;
c. To pay the plaintiff the cost of the suit.
Iloilo City, January 26, 2016.
STEPHEN NIKOLAI L. CRISANG
Counsel for the Plaintiff.
CDE Building
Valeria St., Iloilo City
VERIFICATION AND CERTIFICATION OF
NON-FORUM SHOPPING
Republic of the Philippines )
City of Manila ) S.S.
I, STEVEN JOHNSON, of legal age, Filipino citizen, single and resident
of Lopez Jaena St., Jaro , Iloilo City, after having been duly sworn to in
accordance with law do hereby depose 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 the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or
proceeding involving the same issues in any court, tribunal or quasi-
judicial agency and, to the best of my knowledge, 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
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(5) days therefrom to the court or 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 to comply with the provisions of Adm. Circular No.
04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 26th
of January 2016, in the City of Iloilo.
STEVEN JOHNSON
SUBSCRIBED AND SWORN to before me this 26 th day of January,
2016, in the City of Iloilo, affiant exhibiting to me his TIN 1234-1234-12 issued
on 20th day of March 2010 at Iloilo City, Philippines.
ATTY. JEMIMA RACHEL CRUZ
Notary Public
Until December 31, 2015
PTR No. 1234567
IBP No. 58637
Roll No. 123456
MCLE Compliance No. 000123
