Republic of the PhilippinesMUNICIPAL TRIAL COURT IN CITIES

Branch ____Iloilo City

REYNOLD G. TANZA,               Plaintiff,                                                                          Civil Case No. _____          -versus-                               FOR: Unlawful Detainer

ARDIE JAY F. DAVIDE,             Defendant.x-------------------------------x

COMPLAINT

PLAINTIFF, through the undersigned counsel and unto this Honorable Court, most respectfully states:

1. That the plaintiff, REYNOLD G. TANZA, is of legal age, Filipino citizen, single, resident of 156 Brgy. Sambag, Jaro, Iloilo City, and the defendant, ARDIE JAY F. DAVIDE, is of legal age, Filipino citizen, single, resident of Brgy. Poblacion, Sebaste, Antique, where they may be served with summons and other court processes;

2. That the plaintiff is the owner of a 200 square-meter lot over which an apartment had been constructed located at 123 Cruz St., La Paz, Iloilo City;

3. That on April 30, 2011, the plaintiff entered into a written contract with defendant whereby the former leased to the latter the above described property for the period of three (3) years, starting on August 1, 2011, for the monthly rental of Twenty Thousand Pesos (P20,000), copy of which contract of lease is attached hereto as Annex “A”;

4. That by virtue of the said contract, Annex “A”, defendant took possession of the property in question on August 3, 2010, and he is still in possession of the same up to the present time;

5. That the period stipulated in the contract, Annex “A”, has already expired last August 3, 2014;

6. That despite repeated demands, defendant still refused to vacate the subject property. A copy of the final demand sent to defendant is herein attached as Annex “B”;

7. That as a consequence of defendant’s refusal to vacate plaintiff’s property, the plaintiff was compelled to file this complaint engaging the services of counsel in the amount of PhP 30,000.00.

PRAYER

  WHEREFORE, plaintiff most respectfully prays unto this Honorable Court that, after due hearing, judgment be rendered in his favor ordering the defendant to vacate the premises and to return the possession thereof to plaintiff plus costs.

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

Iloilo, Philippines, March 20, 2015.

ATTY. VINCENT ENRIQUE A. VARONA Counsel for the Plaintiff

Varona Law Office, Alta Tierra Village, Jaro, Iloilo City Roll of Attorneys No. 54321

PTR NO. 654321, 01/06/14, Iloilo City IBP NO. 123456, 01/04/14, Iloilo City

MCLE Comp. No. IV-0009876, 01/02/14

Republic of the Philippines )City of Iloilo )S.S.x---------------------------------------x

VERIFICATION AND CERTIFICATIONOF NON-FORUM SHOPPING

I, REYNOLD G. TANZA, of legal age, single, Filipino and resident of 156 Brgy. Sambag, Jaro, Iloilo City, Philippines after having been duly sworn in accordance with the law, hereby depose and say:

1. That, I am the plaintiff in the above-stated case;

2. That, I have caused the application of the foregoing pleading;

3. That, I have read the contents thereof and the facts stated therein are true and correct of my personal knowledge and/or on the basis of copies of documents and records in my possession;

4. That I have not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or any other tribunal or agency;

5. That to the best of my knowledge and belief, no such action or proceeding is pending in the Supreme Court, the Court of Appeals, or any other tribunal or agency;

6. That if I should thereafter learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or any other tribunal or agency, I undertake to report that fact within five (5) days therefrom to this Honorable Court.                                                                          IN WITNESS WHEREOF, I hereunto set my hand this 20 th day of

March, 2015 at Iloilo, Philippines.

REYNOLD G. TANZAAffiant

Driver’s License No.: F01-118-897Valid until: December 30, 2015

SUBSCRIBED AND SWORN TO before me this 20th day of March, 2015 at Iloilo, Philippines, affiant having exhibited to me his Driver’s License as above stated as competent evidence of identity.

ATTY. VINCENT ENRIQUE A. VARONA Notary Public for and in the City and Province of Iloilo

My Commission No. is 58 Expires on December 31, 2015

Varona Law Office, Alta Tierra Village, Jaro, Iloilo City Roll of Attorneys No. 54321

PTR NO. 654321, 01/06/14, Iloilo City IBP NO. 123456, 01/04/14, Iloilo City

MCLE Comp. No. IV-0009876, 01/02/14

Doc. No. 8;Page No. 3;Book No. 1;Series of 2015.