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Republic of the PhilippinesREGIONAL TRIAL COURT

7th Judicial RegionBranch UVCebu City

HANSEL R. JALALON, Plaintiff

- versus -

MARC REYES

Defendant

x-----------------------------------------x

COMPLAINT

COMES NOW, the plaintiff by the undersigned counsel to this most Honorable Court, MOST RESPECTFULLY STATES THAT;

PARTIES

1. The Plaintiff, HANSEL R. JALALON, is a Filipino citizen, of legal age, single and a resident of Upper Level, 3rd Door Vailoces Apartment, Rahmann Street, Gorordo Avenue Cebu City where she may be served with copies of notices, orders and other papers of this Honorable Court;

2. The defendant, Marc Reyes, is a Filipino, of legal age, single and a resident of Door 1 Ground Floor, T. Padilla Street Cebu City where she may be served with copies of notices, orders and other papers of this Honorable Court;

CIVIL CASE NO. P 1232-15-PGFor Unlawful Detainer

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FACTS OF THE CASE

3. The plaintiff is the owner of a land over which an apartment had been constructed located Rahmann Extension, Gorordo Avenue Cebu City;

4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid apartment for a consideration of P20,000.00 a month as rental to be paid within the first ten (10) days of each month starting November 3, 2014;

5. The defendant failed to pay the agreed rental for several months starting February 19, 2015 up to the present;

6. On May 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”;

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 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 the amount of P10,000.00.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that judgement be rendered in favor of the plaintiff and that after judgement:

a. To vacate the subject premises;

b. To pay the amount of P20,000.00 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.

d. Other just and equitable reliefs and remedies under the premises.

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Cebu City, Philippines, this 5th day of June 2015.

ATTY. MARC GRETEL R. MADANGUITCOUNSEL FOR PLAINTIFFGF 1, Dr. 6 Rahmann Ext., Gorordo Ave. Cebu City ROLL NO. 48511 / 24 Jan 2005IBP Lifetime Roll No.: 816036/ 25 Jan 2005MCLE COMPLIANCE No. III-004319 / 8 Aug 2018PTR No.: 885167; 3/14/15; Cebu City

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VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, HANSEL R. JALALON, of Legal age, single, Filipino Citizen and a resident of Upper Level, 3rd Door Vailoces Apartment, Rahmann Street, Gorordo Avenue Cebu City, after being sworn according to law, hereby depose and state that;

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

2. I caused the preparation of the foregoing complaint;

3. 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. 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. 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. 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.

HANSEL R. JALALON

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and for the Province of Cebu this 5th day of June 2015. Affiant personally came and appeared with her Professional Regulations Commission ID Number 128-957-320 issued by Professional Regulations Commission’s Office of the Province of Cebu on January 24, 2010 at Cebu City, bearing her photograph and signature, known to me as the same person who personally signed this foregoing

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Doc. No. 321Page No. 3Book No. 567Series of 2015

instrument before me and avowed under the penalty of law to the whole truth and contents of the said instrument.

ATTY. JUAN ISMAEL DE LA CRUZGround Flr, 1st Dr, Vailoces Apartment, Rahmann Street, Gorordo Avenue, Cebu CityCOMMISSION NO.: 1234-1234NOTARY PUBLIC for Cebu CityUNTIL December 31, 2018OFFICE: Big Bldg, Door 308, Cebu CityROLL NO. 48511 / 24 Jan 2005IBP Lifetime Roll No.: 816037/ 25 Jan 2005MCLE COMPLIANCE No. III-004319 / 10 Aug 2018TIN 128-957-329