REPUBLIC OF THE PHILIPPINES

FIRSTJUDICIALREGION
REGIONAL TRIAL COURT
Cordillera Administrative Region
Branch 14, Baguio City
GIL N. OLANGAN,
Plaintiff,
Civil Case No. 000884-HQ-R
FOR: SUM OF MONEY

- versus ESTEFANIA A.DORA,

Defendant.
x ------------------------------------ x

COMPLAINT
COMES NOW, plaintiff, by counsel and unto this Honorable Court, respectfully
states that:
1. Plaintiff is a Filipino, of legal age, Filipino Citizen, single, with address at No. 444
Meringue St. Tantocoville, Baguio City where he may be served with summons
and other processes;
2. Defendant is also a Filipino, of legal age and resident of 777 Palmoneres,
Illusurio Drive, Baguio City, where he may be served with summons and other
processes;
3. Sometime between June and July 2015, I was selling my 2 bedroom
condominium unit at Luxury Homes Complex, Baguio City. Through
acquaintances, ESTEFANIA A. DORA came to know of the same and we started
negotiations. From an initial selling price of ONE MILLION AND TWO HUNDRED
AND FIFTY THOUSAND PESOS (1,250,000.00 Php) we closed our deal at an
agreed price of NINE HUNDRED THOUSAND (P900.000.00 Php);
4.

We agreed that the payment of the sum of NINE HUNDRED THOUSAND

PESOS (900,000.00 Php) for the 2 bedroom condominium unit will be on a
staggered basis provided that an initial payment of THREE HUNDRED
THOUSAND PESOS (300,000.00 Php) will be made and thereafter payments
shall be by monthly installments of TWO HUNDRED THOUSAND PESOS
(200,000.00 Php) for the next three (3) months. Payments on installment shall is
due on the 20th of each of the succeeding months starting AUGUST 2015 in
fulfillment of the payment of the whole purchase price;

5. That the said deadline in order to fully pay the amount of NINE HUNDRED
THOUSAND PESOS (900,000.00 Php) is on the 20 th of October 2016
6. On the last week of July 2015, ESTEFANIA A. DORO gave me
THREEHUNDRED THOUSAND (300,000.00 Php) as the agreed initial payment;
7. That on the 20th of August 2015, the date when the first installment payment of
TWO HUNDRED THOUSAND PESOS (200,000.00 Php) was due, no such
payment was made;

8. And again, on the 20th of September 2015, the date when the second installment
payment of TWO HUNDRED THOUSAND PESOS (200,000.00 Php) was due,
no such payment was made;
9. Yet still, on the 20th of October 2015, the date when the third installment payment
of TWO HUNDRED THOUSAND PESOS (200,000.00 Php) was due, no such
payment was made;
10. When the final due date arrived for the supposed payment of the entire purchase
price of my condominium unit in Luxury Homes Complex, Baguio City and
despite repeated demands thereafter, both oral and written, defendant failed or
refused to pay said amount;
11. Resort to the Barangay Conciliation process proved fruitless as defendant failed
to appear, despite notice on him to appear. Thus, a Certification to File Action, a
copy of which is attached as ANNEX A, was issued by the Barangay Chairman.
12. Defendants obligation is due and demandable and plaintiff is entitled to the
payment of the entire amount SIX HUNDRED THOUSAND PESOS (600,000.00
Php) plus legal interest;
13. By reason of defendants unreasonable failure or refusal to pay his due and
demandable obligation, plaintiff was forced to engage the services of counsel to
vindicate his rights thereby committing himself to pay legal expenses amounting
to SEVENTY FIVE THOUSAND PESOS (75,000.00 Php).
WHEREFORE, plaintiff respectfully prays for judgment in his favor through a
Decision directing defendant to pay him SIX HUNDRED THOUSAND PESOS
(600,000.00 Php), with legal interest, as ACTUAL DAMAGES and FIFTY THOUSAND
PESOS (75,000.00 Php) as Attorneys Fees.
Other just and equitable reliefs are also prayed for.
This 10th day of March 2016, in the City of Baguio, Philippines.

ATTY. OSMOND VOM HAMBLIN

Counsel for Plaintiff
9th Chow Echo Suite, 3 North Drive, Baguio City
Telephone No. (074) 444- 3322
PTR No. 23456; 1/2/2019; Baguio City
IBP OR No. 909099; 2/04/2018; Baguio City Chapter
Attorneys Roll No. 60000; 09/22/2018
MCLE Compliance No. VI-7878787; 01/1/2018
REPUBLIC OF THE PHILIPPINES
DONE: IN THE CITY OF BAGUIO

}
} S.S.

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, GIL N. OLANGAN, of legal age, after having been duly sworn in accordance
with law, depose and state that:
1. I am the complainant in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are true and correct of my
personal knowledge and/or on the basis of copies of documents and records in my
possession;
4. I attest to the authenticity of the annexes hereof;
5. I have not commenced any other action or proceeding involving the same issues in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;
6. To the best of my knowledge and belief, no such action or proceeding is pending in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;
7. If I should thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to this Honorable
Court.
IN WITNESS WHEREOF, I have hereunto affix my signature this 10th day of
March 2016 in the City of Baguio, Philippines.

GIL N. OLANGAN
Affiant
PRC License No. 909090
Issued: 2/29/2008; Baguio City
SUBSCRIBED AND SWORN to before me, in the City of Baguio, this 10 th day of
March 2016, by the affiant who has satisfactorily proven his identity to me through his
PRC License indicated below his name, that he is the same person who personally
signed the foregoing document before me and who acknowledged that he executed tha
same.

Doc. No 15
HENRIETTA
Page No. 03
TANGONAN
Book No.2
LASUDEN

BAGUIO
CITY,
PHILIPPI
Series of 2016

ATTY. HENRIETTA TANGONAN LASUDEN

NOTARY PUBLIC
Until December 2020
4th Floor Jose De Leon Building,
38 Upper Session Road, Baguio City
Telephone No. (074) 442- 7845
PTR No. 89898; 2/14/2018; Baguio City
IBP OR No. 642741; 1/04/2017; Baguio City Chapter
Attorneys Roll No. 62741; 09/12/2020
Commission Serial No.: 44-JH-14

Notary Public
Roll No. 62741

MCLE Compliance No. VI-4567890; 02/21/2018

TIN No. 436-820-438-000