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-versusJUAN JAMERO
Defendant.
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C O M PLAI N T
Plaintiff, through the undersigned counsel unto this Honorable Court,
hereby respectfully states as follows:
1) Plaintiff, is of legal age, single, Filipino, and a resident of 111
Libertad St., Sampaloc, Metro Manila, Philippines while the Defendant is
also of legal age, single, Filipino, and a resident of 222 Juan Luna St.,
Tondo, Metro Manila, Philippines where summons and court proceedings
may be served;
2) That, the Defendant borrowed from the Plaintiff a sum of money
amounting to ONE MILLION pesos (P1,000,000.00), with 12% interest per
annum, as evidenced by a Promissory Note herein attached as Annex A
and form an integral part of the complaint;
3) That, the indebtedness of the Defendant has become due and
demandable on January 3, 2009, a year after it was promised in the
promissory note;
4) That, despite repeated verbal and written demands made by the
Plaintiff upon the Defendant, the Defendant has failed to fulfill his
obligation as evidenced by Annex B;
5) That, the Plaintiff in order to enforce his rights and interests, has
sought the service of a legal counsel with attorneys fees amounting
P75,000.00 and an appearance fee of P3,000.00 for every appearance in
court as evidenced by Annex C;
ALEXANDER SISON
Affiant