Вы находитесь на странице: 1из 4

REPUBLIC OF THE PHILIPPINES

Regional Trial Court


6th Judicial Region
Branch_____, Iloilo City

MANILYN PALMA,
Plaintiff,
- versus -

Civil Case No.________________


For: Sum of Money,

JUAN SIMPAS,
Defendant.
x--------------------------------------------------x
COMPLAINT
PLAINTIFF, by counsel, unto this Honorable Court most
respectfully alleges:
1.
That Plaintiff is of legal age, married, Filipino and residing at Brgy.
Magsaysay, Lapaz, Iloilo City, whereasdefendant is likewise a Filipino, of
legal age, single and residing at 222 Juan Luna St., Lapaz, Iloilo City, at
which addresses the parties herein may be served with summons and other
court processes;
2.
That on 03 January 2011, defendant borrowed from plaintiff the
amount of One Million Pesos (P1,000,000.00), which indebtedness is due
and payable on or before 03 January 2014, with an interest at the rate of
Twelve percent (12%) per annum, in accordance with the promissory note
executed by the defendant on the said date.
3.
That a photocopy of the said promissory note is hereto attached as
ANNEX A.
4.
That the defendant has failed and refused and still fails and refuses to
pay the said indebtedness on due date, with the corresponding interest
thereon to the herein plaintiff, despite repeated request and demand.

PRAYER
WHEREFORE, it is most respectfully prayed of this Honorable
Court that after due hearing and trial, judgment be rendered in favor of
plaintiff and against the defendant in this manner:
1.
Ordering the defendant to pay plaintiff the amount of
One Million Pesos (P1, 000,000.00) plus Seven Hundred Twenty
Thousand (P120, 000.00) representing the total annual interest.
2.

Ordering the defendant to pay the cost of this suit.

Plaintiff likewise prays for such other and further relief or relief or
reliefs as this Honorable Court may deem just and equitable in the
premises.
Iloilo City, Philippines, 02 December 2015.
ATTY. JOELYN P. SARCENO-ASPELA
Counsel for plaintiff
No. 24 Puerto Real, La Paz, Iloilo City
Notarial Commission Reg. No. 101
Valid until December 31, 2015
PTR No. 45276, Iloilo City, January 9, 2014
IBP No. 678211, Iloilo City, January 2, 2014
Roll No. 465241, TIN: 03-172-667-21
MCLE Compliance No. IV-0003563

REPUBLIC OF THE PHILIPPINES )


CITY OF ILOILO
) S.S.
x--------------------------------------------------x
VERIFICATION AND CERTIFICATION
I, MANILYN PALMA, of legal age, married, Filipino and a resident of
Brgy. Magsaysay, Lapaz, Iloilo City, after having sworn to in accordance
with law, hereby depose and state:
1. That I am the Plaintiff in the above-entitled case.
2. That I caused the preparation of this complaint, and have read it; and
the contents thereof are true and correct of my personal knowledge
and as based on the records on hand.
3. That I further certify that I have not commenced any action or filed
any claim involving the same issued in any court, tribunal or quasijudicial agency, and there is no other action or claim pending therein;
that if there is any such pending action or claim or similar action or
claim is pending, I shall immediately report that fact to this Honorable
Court, within five (5) days from knowledge thereof.
IN WITNESS THEREOF, I hereunto affix my signature this 2nd day
of December, Iloilo City, Philippines.
MANILYN PALMA
Affiant

SUBSCRIBED AND SWORN TO before me this 2nd day of


December 2015, at Iloilo City, Philippines, affiant exhibiting to me his
Drivers License No. 0926745688 issued in Iloilo City on 11th day of
November 2015.
ATTY. CARLO E. HIFARVA
No. 24 Puerto Real, La Paz, Iloilo City
Notarial Commission Reg. No. 91
Valid until December 31, 2015
PTR No. 567893, Iloilo City, January 9, 2015
IBP No. 3456732, Iloilo City, January 2, 2015
Roll No. 65478, TIN: 02-784-984-71
MCLE Compliance No. IV-0008764

Doc. No._____;
Page No._____;
Book No. ____;
Series of 201__

Вам также может понравиться