REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

11th JUDICIAL REGION
City of Tagum
Branch 31

MAXINNE M. MEDINA,
Plaintiff,
CIVIL CASE No. ______
-versus- FOR: Unlawful Detainer

PIA A. WURTZBACK,
Defendant.

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COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable
Court, most respectfully avers:

1. That the plaintiff, MAXINNE M. MEDINA, is of legal age, Filipino citizen, single, with
residence and postal address at P1 Kalye Pogi St., Buclad, Asuncion, Davao del Norte;

2. That the defendant, PIA A. WURTZBACK, is of legal age, Filipino citizen, single, with
residence and postal address at P5 Katipunan, Kapalong, Davao del Norte where they
may be served with summons and other court processes;

3. The plaintiff is the owner of a land over which house for rent had been constructed,
located at 123 Doctolero Ave., Tagum City;

4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid
apartment for a consideration of P15,000.00 a month as rental to be paid within the first
ten (10) days of each month starting November 3, 2010;

5. The defendant failed to pay the agreed rental for several months starting October 19,
2016 up to the present;

6. On January 3, 2012, the plaintiff sent a letter of demand to vacate the house 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 vacate the house;

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 P30,000.00.

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 P15,000.00 per month as compensation for the reasonable use of
the subject premises until they finally vacate the said premises;

3. To pay the plaintiff the cost of the suit.

City of Tagum, January 27, 2017.

ATTY. MARY JUSTICE P. AURELIO, CPA

 Counsel for the Plaintiff
Door 5, Consuelo Commercial Building,
Pionner Ave., Mankilam, Tagum City
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Tagum
PTR No. 87654/01-05-17/Tagum

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Tagum ) S.S.

I, MAXINNE M. MEDINA, of legal age, Filipino citizen, single and resident of P1 Kalye
Pogi St., Buclad, Asuncion, Davao del Norte, 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 (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 27th of January, 2017,
in the City of Tagum.

MAXINNE M. MEDINA

SUBSCRIBED AND SWORN to before me this 27 th day of January, 2017, in the City of
Tagum, affiant exhibiting to me his Drivers License No. 12345 issued by the Land
Transportation Office on April 8, 2016 at the City of Tagum.

ATTY. MARY JUSTICE P. AURELIO, CPA

Counsel for the Plaintiff
Door 5, Consuelo Commercial Building,
Pionner Ave., Mankilam, Tagum City
Roll of Attorney No. 98765
IBP No. 12345/2-5-12/Tagum
PTR No. 87654/01-05-17/Tagum

Doc. No. 5
Page No. 15
Book No. 1
Series of 2017.