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4. Respondent has continued to occupy the said apartment notwithstanding the fact thathe failed to pay the lease for two (2) consecutive months violating the Contract of Leaseagreement thus depriving the plaintiff from having the said apartment leased by other

persons;

5. Several demands to vacate was made by plaintiff to respondent, although orally, butrespondent refused to vacate the said apartment and return possession to the plaintiff;

6. On September 22, 2015 , plaintiff sent a letter to respondent as a last and final demandfor respondent to vacate plaint iffs apartment; ( Copy of Demand Letter is hereto attached as

Annex B)

7. Until now Respondent still refuse to vacate and restore possession and pay his rentalsfor the months of August, and September, 2014 during his occupation of the apartment;

8. Thus, Respondent is unlawfully withholding possession of the subject apartmentfrom the plaintiff despite last and final demand, to the damage and prejudice of the

plaintiff;

9.Before filing of this complaint, the dispute has been referred to the Lupong

Tagamayapa of Cabanatuan City but the parties failed to arrive at an amicable

settlement; (Certificate to File Action is hereto attached as Annex C)

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court 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 (P 20,000.00) PHILIPPINE

CURRENCY, representing the arrears of rent now overdue.

3. To pay the costs for this suit.

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Other reliefs just and equitable under the premises are likewise prayed for.

Cabanatuan City, Philippines, November 29, 2015.

MINI LAW OFFICECounsel for Plaintiff

Rm. 123, 21rd Floor, Very small Building,Cabanatuan City

By:

ATTY. BUY N. SEHL PTR No: 0116199 (2016)IBP No.:101682 (2016)

MCLE Compliance No.: III-0025943 (2016)Roll No.: 246951