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ALEX NAVARRO,
Defendant.
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COMPLAINT
Jessica Pekpek, plaintiff, thru counsel, and unto this Honorable Court,
respectfully alleges:
1. The plaintiff, Jessica Pekpek, and the Defendant, Alex Navarro, are
both of age and residents of Villasis, Santiago City;
2. On March 11, 2011, Alex Navarro obtained a loan from Jessica
Pekpek in the sum of EIGHT HUNDRED THOUSAND PESOS (Php
800,000.00) to be paid one year after date or March 12, 2012;
3. Said loan, now overdue, is evidenced by a written agreement signed
both by the plaintiff and defendant, a copy of which is hereto attached
as an annex A and made and integral part of this complaint;
4. On or about March 2012, Jessica Pekpek verbally demanded from
Alex Navarro the payment of such loan but the later did not pay and
promised to pay the same on the first week of August 2012;
5. On or about the first week of August 2012, Jessica Pekpek again
verbally demanded from Alex Navarro the payment of money but the
latter, once again, did not pay and instead promised to pay on the third
week of September 2012.
JESSICA PEKPEK
Complainant
VERIFICATIONWITHCERTIFICATIONOF
NONFORUMSHOPPING
JESSICA PEKPEK
Complainant
TH
Doc No.
067
Page No.
04
Book No.
012
Series of 2015
Jessica Pekpek
Creditor
Witnesses:
Arnold Clavencio
Kagawad
Karen Davil
Kagawad
Alex Navarro
Debtor
10 December 2013
ALEX NAVAROO
P7 Villasis, Santiago City
Sir:
This letter isin behalf of my client, Ms. Jessica Pekpek, the matter of your nonpayment of your obligation.
Records disclose that you have an outstanding obligation with our client in the
amount of Php800,000.00 exclusive of interest. Despite repeated demands, you
failed and continuously fail to pay the aforesaid amount.
Accordingly, FINAL DEMAND is hereby made upon you to settle the amount
ofPhp800,000 within FIFTEEN (15) days from receipt of this letter. Otherwise,
we will be constrained to file the necessary legal action against you to protect the
interest of my client.
I trust that you will give this matter your prompt and preferential attention to avoid
the expense and inconvenience of litigation.
Truly yours,