COMPLAINT


      COMES NOW the plaintiff, by the undersigned counsel, and unto this Honorable Court, respectfully alleges:

      1. That the plaintiff is of legal age and presently residing at _______________, while the defendant is also of legal age and residing at _______________;

      2. That the plaintiff is the absolute owner and lessor of that certain residential house located at ______________, and now leased and occupied by the defendant;

      3. That the defendant leases and occupies the said residential house under the express obligation of paying a rent of P_______ a month, payable in advance within the first five (5) days of every month;

      4. That the defendant has not paid the rents for the said residential house for the months of ________ and __________ of the current year;

      5. That furthermore, the defendant has failed to comply with the conditions of his lease, namely, __________________________;

      6. That the plaintiff has several times demanded of the demanded to vacate the above premises and to pay his back rentals, now amounting to P________, the last demand having been made on him personally and in writing on ________ or more than five (5) days before the filing of this complaint.

      WHEREFORE, it is respectfully prayed that, after due hearing, judgment be rendered in favor of the plaintiff:

           (a) For the restitution of the above mentioned premises;

           (b) For the payment of P________, representing the arrears of rent now overdue, with legal interest from the filing of the complaint, and costs of this suit;

           (c) For attorney's fees in the amount of P__________.

      City of Manila, on this ____ day of _________, 2004.



JUAN DE LOS SANTOS
Counsel for the Plaintiff

(Address, IBP & Roll No.)

VERIFICATION AND JURAT




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