DEMAND LETTER Ejectment

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FINAL DEMAND LETTER

FOR
PAYMENT OF RENT

January 10, 2020

Mr. Mario A. Kart


Door 3, Apartment Heights
Cabaguio St., Davao City

Dear Mr. Mario,

Based on the authority of our client Mr. LUIGI L. LENGUIN, owner of the Door
3, apartment unit located at Apartment Heights, Cabaguio St., Davao City

You are informed that you have failed to pay your rental for six (6) months, which
have now amounted to TWO HUNDRED THOUSAND PESOS (Php 200,000.00).

We are reminding you that our client has sent you a number of demand letters
asking you to pay your rentals and to vacate the premises. However, the same letters have
been left unanswered.

Let it be known then, that this letter is our client’s FINAL DEMAND for you to
PAY YOUR ACCOUNT within FIVE (5) DAYS from receipt and to VACATE THE
premises within FIVE(5) DAYS from receipt of this notice. Otherwise, you left our client
with no choice but to commence suit to protect his interests.

Respectfully yours,

ATTY. JAN-LAWRENCE P. OLACO


Counsel for Mr. Luigi L. Lenguin
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
REGION XI
DAVAO CITY, BRANCH 10

LUIGI L. LENGUIN
Plaintiff,

---- versus ---- Civil Case No. 22002


For: Ejectment

MARIO A. KART
Defendant

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, single and currently resides at Brgy. Ma-a,
Davao City; Defendant is a Filipino, of legal age, single and current resident of Door 3,
Apartment Heights, Cabaguio St. Davao City, where he may be served with summons and
other pertinent processes.

2. Plaintiff owns that property located at Door 3, Apartment Heights, Cabaguio St.
Davao City which it leased to defendant for a term of 2 years starting on January 10, 2019,
at a monthly rate of (P 33,333.00).

3. Defendant, however, has not paid his rent for six (6) months from June 10, 2019
to November 10, 2019.

4. Despite demand duly made and received, defendant has refused to vacate the
premises and continues to occupy the property without plaintiff’s consent.

5. Defendant’s act of dispossession has caused plaintiff to suffer material injury.


Defendant’s continued occupation of the premises has also forced plaintiff to sue and to
incur legal expenses amounting to FIFTY THOUSAND PESOS (P50,000.00).

PRAYER

WHEREFORE, plaintiff respectfully prays for judgment in its favor by ordering


defendant to vacate the property and peacefully turn over possession to plaintiff and for
defendant to pay plaintiff the amount of TWO HUNDRED THOUSAND PESOS (P
200,000.00) representing rentals of the house and lot for SIX (6) months and FIFTY
THOUSAND PESOS (P 50,000.00) for Attorney’s fees.

Other just and equitable reliefs are also prayed for.

Respectfully submitted.

City of Davao, Philippines, January 17, 2020.


REPUBLIC OF THE PHILIPPINES)
CITY OF DAVAO ) S.S.
x----------------------------------------------x

VERIFICATION and CERTIFICATE


OF
NON FORUM SHOPPING

I, LUIGI L. LENGUIN, of legal age, after having been duly sworn in accordance with
law, 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.

LUIGI L. LENGUIN
Affiant

SUBSCRIBED AND SWORN TO before me on this 17TH day of January, 2020,


affiant exhibiting before me his Driver’s License no. 28991-00 issued on 10th day of
January, 2020 in the City of Davao, Philippines.

Doc. No. ____;


Page no. ____;
Book no. ____;
Series of _____.

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