REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

BRANCH 8
BAGUIO CITY

RANDY L. SINGER,
Plaintiff, CIVIL CASE NO. 627
For: Unlawful Detainer
-versus-

JOHN R. GRISHAM,
Defendant.

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

COMPLAINT

Plaintiff, by counsel and unto this Honorable Court, most respectfully

avers that:

1. Plaintiff, RANDY SINGER, is a Filipino citizen, of legal age, single and with
residence and postal address at #2 Sanitary Camp, Baguio City;

2. Defendant, JOHN GRISHAM, is also a Filipino citizen, of legal age, single

and with residence and postal address at #22 Kias, Baguio City;

3. Plaintiff is the owner of an apartment located at #3 Sanitary Camp,

Baguio City, covered by Transfer Certificate of Title No. 50905 (Annex “A”);

4. By virtue of a contract of lease (Annex “B”), Plaintiff leased to Defendant

the said apartment for a consideration of Php8,000.00 a month as rental to
be paid within the first ten (10) days of each month starting January 6,
2016;

5. From January 1, 2017 up to the present, Defendant failed to pay the

agreed rental;

6. On February 11, 2017, Plaintiff sent a demand letter (Annex“C”) to

Defendant for him to vacate the apartment and pay the agreed rentals,
which was received by Defendant, as shown in the registry return receipt
(Annex “D”);

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7. Despite said demand letter and repeated oral demands, Defendant failed
and still refused to pay the agreed amount of rentals and to vacate the
apartment;

8. On March 7, 2017, Plaintiff brought the matter before the Barangay

Authorities for conciliation but no settlement was reached (Annex “E”);

9. By reason of failure of Defendant to vacate the premises and to pay the

unpaid rentals, Plaintiff was compelled to file this Complaint engaging the
services of counsel in the amount of P50,000.00.

PRAYER

WHEREFORE, premises considered, Plaintiff most respectfully prays

unto this Honorable Court that, after hearing, judgment be rendered
ordering Defendant:

1. To vacate the subject premises;

2. To pay the amount of P8,000.00 per month as compensation for the

reasonable use of the subject premises until he finally vacates it; and

3. To pay Plaintiff the cost of the suit.

Other reliefs, just and equitable, are likewise prayed for.

Baguio City, March 16, 2017.

Counsel for the Plaintiff

Copy Furnished (by personal service):

ATTY. ABU D. GADO
Counsel for the Respondent

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 VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, RANDY L. SINGER, of legal age, after having been duly sworn in

accordance with law, depose and state that:

1. I am the 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.

RANDY L. SINGER
Affiant

SUBSCRIBED AND SWORN to before me this 16th day of March, 2017 at

City of Baguio, Benguet, Philippines affiant exhibiting to me his Driver’s
License ID No. 782, issued at Baguio City on August 1, 2015.

Doc. No. ___

Page No. ___
Book No. ___
Series of 2017

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