Complaint For Ejectment (Unlawful Detainer)

REPUBLIC OF THE PHILIPPINES
MUNICIPAL TRIAL COURT IN CITIES

ILOILO CITY
BRANCH__
YASSY Y. PRESSMAN
Plaintiff,
CIVIL CASE NO. 2017-156
-versus- For: Unlawful Detainer
COCO C. MARTIN,
Defendant,
x -----------------------------------x
COMPLAINT
COMES NOW the plaintiff by the undersigned attorney, and unto

this Honorable Court, respectfully avers:
1. That plaintiff is a Filipino, of legal age, married and residing at

Brgy. Benedicto, Jaro Iloilo City, whereas defendant is likewise a
Filipino, of legal age, married and residing at Brgy. Monica, City
Proper Iloilo City, at which addresses the parties herein may be
served with summons and other court processes;
2. That the plaintiff is the absolute owner and lessor of that certain
building located at MV Hechanova, Jaro, Iloilo City;
3. That the defendant leases and occupies the said building under
the express obligation of paying a rent of P50,000.00 a month,
payable in advance within the first five (5) days of each month
starting November 2016;
4. That the defendant has not paid the rents for the said building for
several months starting December 2017 up to the present;
5. On February 6, 2017, the plaintiff, through counsel sent a letter
to respondent as a last and final demand for respondent to vacate
plaintiffs building; (Copy of Demand Letter is hereto attached as
Annex A)
1
6. 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 building;
7. 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.
WHEREFORE, it is most respectfully prayed of this Honorable

Court that after due hearing, judgment be rendered in favor of plaintiff
and against defendant in this manner:
1. To vacate the subject premises;
2. To pay the amount of P50,000.00 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 costs of this suit.
Plaintiff likewise prays for such other and further relief or reliefs as
this Honorable Court may deem just and equitable in the premises.
Iloilo City, Philippines, March 6, 2017.
____________________________________
SHANE MARIE BELLOGA - EDROSOLANO
Counsel for Plaintiff
Arguelles Bldg., Jaro, Iloilo City
Roll No.: 110928
PTR No.: 1112345 06-30-2016 Iloilo City
IBP No.: 176184 06-30-2016 Iloilo City
MCLE Compliance No.: 455813 08-05-2016
2
VERIFICATION AND CERTIFICATION
I, YASSY Y. PRESSMAN, of legal age, married, Filipino and a

resident of Brgy. Benedicto, Jaro Iloilo City, under oath depose and
state that:
a. I am the Plaintiff in the above captioned case;
b. I have caused the preparation of the same and have read

the allegations contained therein;
c. The allegations in the said complaint are true and correct

of my own knowledge and authentic records;
d. 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;
e. 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;
f. 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 set my hand this 6 th day of

March 2017 at Iloilo City, Philippines.
___________________
Affiant
SUBCRIBED AND SWORN TO before me this 6th day of March

2017 in Iloilo City, Philippines, affiant exhibiting to me her City
Government ID no. 2016-067 issued in Iloilo City on March 10, 2016
and valid until June 30, 2019.
3
SHANE MARIE BELLOGAEDROSOLANO
Notary Public for the City & Prov. of Iloilo
Until December 31, 2018
Arguelles Bldg., Jaro, Iloilo City
Roll No.: 110928
PTR No.: 1112345 06-30-2016 Iloilo City
IBP No.: 176184 06-30-2016 Iloilo City
MCLE No.: 455813 08-05-2016
Doc. No. __12_;

Page No. __2__;
Book No. __2__;
Series of 2017.
4
6 February 2017
Coco C. Martin
Brgy. Monica, City Proper Iloilo City
Sir:
This is in connection with your unpaid rentals covering the period December
2016 to January 2017 in the total amount of P100,000.00 being referred to
me by Mrs. Yassy Y. Pressman, the owner of the building you are occupying,
for legal action warranted under the circumstances.
Repeated demands were made upon you by my client to update your rental
arrearages in violation of the lease agreement and to vacate the premises
you are occupying, but you failed and refused and still fails and refuses to
vacate the same to the damage and prejudice of my client.
Accordingly, demand is hereby made upon you to pay the amount

of P100,000.00 directly to my client within FIFTEEN (15) days from
receipt of this letter. Otherwise, I will be constrained to file the necessary
legal action against you to protect my client's interest without further notice.
Truly yours,
ATTY. SHANE MARIE B. EDROSOLANO

Complaint For Ejectment (Unlawful Detainer)

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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

COMES NOW the plaintiff by the undersigned attorney, and unto

1. That plaintiff is a Filipino, of legal age, married and residing at

7. By reason of failure of the defendant to vacate the premises

WHEREFORE, it is most respectfully prayed of this Honorable

1. To vacate the subject premises;

2. To pay the amount of P50,000.00 per month as

3. To pay the plaintiff the costs of this suit.

Iloilo City, Philippines, March 6, 2017.

I, YASSY Y. PRESSMAN, of legal age, married, Filipino and a

a. I am the Plaintiff in the above captioned case;

b. I have caused the preparation of the same and have read

c. The allegations in the said complaint are true and correct

d. I hereby certify that I have not commenced any other

e. That if I should learn thereafter that a similar action or

f. I executed this verification/certification to attest to the

In witness whereof, I have hereunto set my hand this 6 th day of

SUBCRIBED AND SWORN TO before me this 6th day of March

Doc. No. __12_;

Accordingly, demand is hereby made upon you to pay the amount

ATTY. SHANE MARIE B. EDROSOLANO

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