Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

FIRST JUDICIAL REGION
Branch 2
Baguio City
CIVIL CASE NO.: 23123
Plaintiff,
- versus -

FOR: SUM OF MONEY

,
Defendant,
x--------------------- ---x
COMPLAINT
Plaintiff through the undersigned counsel, into this
Honorable Court, most respectfully states:
1. Plaintiff is of legal age, married, Filipino Citizen and a
resident of No. 3, Purok 2, Fairview, Baguio City,
while defendant is of legal age, married, Filipino
Citizen and a resident of No. 13, Purok 3, Fairview,
Baguio City where they may be served with
summons and other court processes;
2. Sometime on June 15, 2015, the defendant obtain a
loan in the amount of ONE HUNDRED THOUSAND
PESOS ( P100,000.00 ) from the plaintiff payable
within five months with a monthly interest of Five
Percent ( 5 % ) per month. Copy of the Promissory
Note dated January 23, 2015 is hereto attached as
Annex A and made part hereof;
3. Plaintiff through counsel sent a demand letter dated
December 20, 2015 the obligation being due and
demandable which the defendant received and
signed but notwithstanding, the latter failed, refused
and neglected to settle his obligation. Copy of the
demand letter is hereto attached and marked as
Annex B and made integral part hereof;

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4. Due to the unwarranted actions of the defendant, the

plaintiff was constrained to engage the services of
herein counsel to represent her in the above-entitled
case and agreed to pay the amount of TWENTY
THOUSAND PESOS (P20,000.00 ) representing
attorneys fees and TWO THOUSAND PESOS
(P
2,000.00 ) per court appearance.

PRAYER
WHEREFORE, it is respectfully prayed that, pending
the hearing of the case, a writ of preliminary attachment be
issued against the property of the defendant to serve as
security for the satisfaction of any judgment that may be
recovered herein, and after due hearing on the principal
cause of this action, judgment be rendered against the
defendant for the sum of P100, 000 with interest at the
stipulated rate of five per centum per annum (5%) from June
16, 2015 plus cost of the suit.
OTHER RELIEFS reasonable under the premises are
also prayed for.
Baguio City, Philippines; March 15, 2016.

Counsel for the plaintiff

No. 23 Otek Square Bldg., Otek Street, Baguio City
Roll No. 65321; April 10, 2015
PTR No. 2091162; January 10, 2016, Baguio City
IBP No. 2311755; January 15, 2016, Baguio-Benguet Chapter
MCLE COMPLIANCE No. III-098765, January 11, 2015, Pasig
City
Doc. No.4;
Page No. 2;
Book. No. II;
Series of 2016.
Page 2 of 4

VERIFICATION & CERTIFICATION OF NON-FORUM

SHOPPING
Republic of the Philippines )
Baguio City
) S.S.
I, , of legal age, Filipino citizen, single and resident of N
No. 13, Purok 3, Fairview, Baguio City, after having been duly
sworn to in accordance with law do hereby depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing
complaint and have read the allegations contained
therein;
3. The allegations in the said complaint are true and
correct of my own knowledge and authentic records;
4. I hereby certify that I have not commenced any other
action or proceeding involving the same issues in any
court, tribunal or quasi-judicial agency and, to the
best of my knowledge, no such other action or claim
is pending therein;
5. That if I should learn thereafter that a similar action
or proceeding has been filed or is pending, I hereby
undertake to report that fact within five (5) days
therefrom to the court or agency where the original
pleading and sworn certification contemplated herein
have been filed;
6. I executed this verification/certification to attest to
the truth of the foregoing facts and to comply with
the provisions of Adm. Circular No. 04-94 of the
Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my
signature this 15th of March 2016, in the City of Baguio.

SUBSCRIBED AND SWORN to before me this 15 day

of March, 2016, in City of Baguio.
Notary Public
Notarial Commission expires on December 31, 2017
Roll No. 65321; April 10, 2015
PTR No. 2091162; January 10, 2016, Baguio City
IBP No. 2311755; January 15, 2016, Baguio-Benguet Chapter
Page 3 of 4

M.C.L.E. Compliance No. III-098765, January 11, 2015, Pasig

City
Cell No. 09-123-456-789, TIN: 321-654-000
Doc. No.4;
Page No. 2;
Bk. No. II;
Series of 2016.

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