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Complaint For Unlawful Detainer

1. Nancy D. Sy filed a complaint against Glenn S. Uy for unlawful detainer in the Municipal Trial Court of Quezon City. 2. Sy alleges that Uy leased an apartment from her but failed to pay rent, with two rent checks bouncing due to insufficient funds. 3. Despite demands and a 10-day notice, Uy refused to vacate the property or pay outstanding rent, damages, and costs.

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Khay Gonzales
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207 views4 pages

Complaint For Unlawful Detainer

1. Nancy D. Sy filed a complaint against Glenn S. Uy for unlawful detainer in the Municipal Trial Court of Quezon City. 2. Sy alleges that Uy leased an apartment from her but failed to pay rent, with two rent checks bouncing due to insufficient funds. 3. Despite demands and a 10-day notice, Uy refused to vacate the property or pay outstanding rent, damages, and costs.

Uploaded by

Khay Gonzales
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

MUNICIPAL TRIAL COURT


Branch 1
City of Quezon

NANCY D. SY
Plaintiff,

Civil Case No. 12345


For: Unlawful Detainer
GLENN S. UY
Defendant.
x-----------------------------------------x

COMPLAINT

PLAINTIFF, by counsel, most respectfully alleges that

1. The plaintiff is of legal age, Filipino, with residence and postal


address at 777 Examiner St., West Triangle, Quezon City where she
may be served notices and other court processes;

2. The defendant is of legal age, Filipino, with residence and postal


address at 518 NDC Apartments. West 4th St., South Triangle,
Quezon City;

3. The plaintiff is the absolute owner and lessor of the NDC Apartments
situated in Quezon City that is now leased and occupied by the
defendant;

4. Pursuant to the lease contract executed by the plaintiff and the


defendant dated October 28, 2022, the defendant is obliged to pay a
monthly rental payment of P10,000.00 to the plaintiff;

5. A stipulation in the said lease contract provides that in case of default


by the lessee of the payment of the rent such as when the checks are
dishonored, the plaintiff at its option may terminate this contract and
eject the lessee;

6. On January 28, 2023, the plaintiff tried to encash BPI Check No.
25613 corresponding to the rental payment for the month of January
but the same was dishonored due to insufficiency of funds;

7. On the same day, the plaintiff informed the defendant that the latter’s
check was dishonored and demanded that formed be paid in cash
instead but the defendant failed to do so;

1
8. On February 28, 2023, the plaintiff tried to encash BPI Check No.
25614 corresponding to the rental payment for the month of February
but the same was also dishonored due to insufficiency of funds;

9. On the same day, the plaintiff again went to the defendant and
demanded the payment of the two dishonored checks but the
defendant failed to tender payment;

10. On March 15, 2023, the plaintiff, with the assistance of a counsel,
sent a formal demand letter to the defendant giving him ten days to
make his rental payment;

11. On March 25, 2023, at the expiration of the ten-day grace period
given by the plaintiff, the defendant still has not made his payment;

12. Plaintiff thereafter informed the defendant to vacate the premises for
failure to pay rent;

13.Respondent, despite notice, refused to vacate said apartment;

14. Until now, the defendant still refuses to vacate, restore possession of
the unit, and pay his rentals;

15. Thus, the defendant is unlawfully withholding possession of the


subject apartment from the plaintiff despite the last and final demand,
to the damage and prejudice of the plaintiff;

16. Before filing this complaint, the dispute has been referred to the
Lupong Tagapamayapa of Quezon City but the respondent failed to
appear, hence, no amicable settlement was made.

PRAYER

WHEREFORE, the plaintiff prays that, after due notice and hearing,
judgment be rendered in favor of Plaintiff:

1. For the restitution of the abovementioned apartment;

2. For the payment of TWENTY THOUSAND PESOS (P20,000.00),


Philippine currency, representing the arrears of rent now overdue;

3. To pay the cost of the suit.

The plaintiff prays for all other reliefs, just and equitable.

Quezon City, March 31, 2023.

ATTY. BELA REEZE TAN


2
Counsel for Plaintiff
Tan & Associates Law Firm
117 Gamboa St., San Lorenzo, Quezon City

VERIFICATION AND CERTIFICATION OF NON-FORUM


SHOPPING

Republic of the Philippine )


City of Quezon ) S.S.

I, NANCY D. SY, of legal age, after having been duly sworn in


accordance with the law, depose and state that:

1. I am a plaintiff in the above-stated case;

2. I have prepared the submitted complaint;

3. I have read the contents and the facts stated therein are true and
correct of my personal knowledge and 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.

Quezon City, March 31, 2023.

__________________
NANCY D. SY

SUBSCRIBED AND SWORN to before me this 31st day of March


2023 at Quezon City, Philippines affiant exhibiting to me her Passport No.
58158450 issued in DFA Manila 2021.

ATTY. JOSE LAO

3
Notary Public
Until December 31, 2023
Brgy. IV, Quezon City, Philippines
Roll of Attoryney’s No. 123456
PTR No. 12345, 01/01/2023, Quezon
City
MCLE Compliance No. xx-123456,
01/01/2023
Serial No. ___;
Doc. No. ____;
Page No. ____;
Book No.____;
Series of 2023.

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