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MANILYN PALMA,
Plaintiff,
- versus -
JUAN SIMPAS,
Defendant.
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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.
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
Doc. No._____;
Page No._____;
Book No. ____;
Series of 201__