REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

City of Manila
Branch 1

KRUL ACOSTA, Plaintiff,

-versus-
CIVIL CASE No.
98765
FOR: Unlawful Detainer
MEGAN VITUG, Defendant.

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

COMPLAINT

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

1. That the plaintiff, KRUL ACOSTA, is of legal age, Filipino citizen, single, with residence and postal
address at 123 Benitez Street, Manila;

2. That the defendant, MEGAN VITUG, is of legal age, Filipino citizen, single, with residence and postal
address at 456 Modesto Street, Manila, where they may be served with summons and other court
processes;

3. The plaintiff is the owner of a land over which an apartment had been constructed located 654 San
Pedro Street, Manila;

4. By virtue of a contract of lease, the plaintiff leased unto the defendant the aforesaid apartment for a
consideration of P5,000.00 a month as rental to be paid within the first ten (10) days of each month
starting November 3, 2011;

5. The defendant failed to pay the agreed rental for several months starting February 19, 2012 up to the
present;

6. On May 3, 2012, the plaintiff sent a letter of demand to vacate the apartment 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 vacated the apartment;

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
P10,000.00.

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 P5,000.00 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 Manila, September 24, 2012.

REYES, TOLENTINO AND CRUZ LAW OFFICE
Counsel for the Plaintiff Unit 123,
Victoria Tower I Taft Avenue, Manila By:
Louise Reyes Roll of Attorney
No. 98765 IBP No. 12345/2-5-12/Manila PTR No. 87654/12-22-11/Manila

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Manila ) S.S.

I, KRUL ACOSTA, of legal age, Filipino citizen, single and resident of 123 Benitez Street, Manila,
after having been duly sworn to in accord Nance 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 24th of September 2012, in the City of
Manila.

KRUL ACOSTA
 SUBSCRIBED AND SWORN to before me this _______ day of September, 2012, in the City of
Manila, affiant exhibiting to me his Driver’s License No. 12345 issued by the Land Transportation Office
on April 8, 2012 at the City of Manila.

ATTY. NO CASE
Notary Public My
Commission Expires
Dec. 31, 2012 Roll of
Attorney No. 34567

IBP No. 12345/2-5-12/Manila

PTR No.
87654/12-22-11/Manila Doc.
No. ________ Page No.
_______ Book No. _______
Series of 2012.
AFFIDAVIT OF ADVERSE CLAIM

REPUBLIC OF THE PHILIPPINES)

CITY OF MAKATI ) S.S.

AFFIDAVIT OF ADVERSE CLAIM

I, SASHA GREY, of legal age, Filipino, single and a resident of 2223 Washington Street, Pio del Pilar,
Makati City, after having been duly sworn to in accordance with law, depose and state:

1. That on July 10, 2013, I have entered into a Deed of Conditional Sale which was acknowledged on
the same date before Notary Public Juan Tamad of Makati City and entered in his Notarial Register
as Doc. No. 2, Page 2, Book II, Series of 2013. A copy of the said Deed is hereto attached as ANNEX
“A” and made an integral part of this Affidavit;

2. That in the said Deed of Conditional Sale, I was the VENDEE of a certain parcel of land covered by
Transfer Certificate of Title No. 111222, more particularly described as follows: (Technical Description of
Property)

3. That because I still have a balance on the purchase price in the amount of P500,000.00 which is
payable within one (1) (year) from the date of signing thereof, it was stipulated in the aforementioned
Deed that title and ownership over the subject property will only be transferred upon full payment of
the same;

4. That the VENDOR in the said Deed of Conditional Sale agreed that upon its execution, said Deed shall
be annotated in the Title with the Office of the Register of Deeds of Makati City;

5. However, since the said Deed of Conditional Sale per se could not be annotated on the Title with the
Office of the Register of Deeds, I am therefore executing this Affidavit for the purpose of attesting to the
truthfulness of the foregoing allegations and in support of my request for the annotation of an adverse
claim over the parcel of land covered by the Transfer Certificate of Title No. 111222. IN

WITNESS WHEREOF, I have hereunto set my hand this 27TH day of January 2014 in Makati City,
Metro Manila, Philippines.
 SASHA GREY
Affiant

With Philippine Passport No. 123456 SUBCRIBED AND SWORN TO before me this 27TH day of
January 2014 in Makati City, Metro Manila, Philippines, affiant exhibiting to me her Philippine Passport
No. 123456 issued in Manila on January 12, 2012 and valid until January 12, 2017.

Doc. No. _____;

Page No. _____;

Book No. _____;

Series of 2014.