(Complaint for Collection of Sum of Money)

(CAPTION)
COMPLAINT
COMES NOW Plaintiff, by counsel and to this Honorable Court, respectfully states that:
1. Plaintiff _____________ is of legal age, Filipino, (single / married / widow), and a
resident of _____________, Philippines. For purposes of this action, plaintiff may be
served with all orders, notices, and other processes of this Honorable Court through the
office address of the undersigned counsel indicated below;
2. Defendant _____________, of legal age, Filipino, (single / married / widow), and may be
served with summons and other processes of this Honorable Court at his last known
address at _____________, Philippines;
3. Sometime on _____________, Defendant obtained from and was granted a loan
accommodation

by

the

Plaintiff

in

the

principal

amount

of

__________________________ (P_____________), Philippine Currency;

4. A true and faithful machine reproduction of the Promissory Note made by the Defendant
on _____________ is hereto attached as Annex "A";
5. As of _____________, Defendant still has an Outstanding Balance to Plaintiff amounting
to __________________________ (P_____________), Philippine Currency, and has
failed and neglected to pay, without just and valid grounds, the said Outstanding Balance
for the aforementioned loan accommodation;
6. Despite Plaintiff's repeated demands, both written and verbal, Defendant failed, neglected
and refused, and continues to fail and refuse to pay and to settle the said Outstanding
Balance, without just and valid grounds, to the continued damage and prejudice of
Plaintiff;
7. A true and faithful machine reproduction of the Plaintiff's demand letter to Defendant
dated _____________ is hereto attached as Annex "B";
8. Consequently, Plaintiff was constrained to engage the services of counsel to whom it
obligated itself to pay as Attorney's Fees the amount equivalent to _____________
(______%) percent of the total amount due from Defendant to Plaintiff.

PRAYER
WHEREFORE, after due notice and hearing, Plaintiff respectfully prays that judgment
be rendered against the Defendant as follows:
1. Ordering the Defendant to pay Plaintiff the sums of:
a.

The

amount

of

__________________________

(P_____________),

representing Defendant's Outstanding Balance plus interest at the rate of

_____________ (_____%) per month as stipulated upon in the Promissory
Note;
b.

_____________ (_____%) percent of the total amount due as Attorney's Fees

plus Appearance Fee at the rate of P__________ per court hearing /
conference;

c.

_____________ (_____%) percent of the total amount due as Collection

Charges / Liquidated Damages;

d.

The costs of suit.

2. Plaintiff respectfully prays for such other reliefs as may be just and equitable in the
premises.
Date _____________, Philippines, __Date__.

(COUNSEL)
(VERIFICATION)
(CERTIFICATION OF NON-FORUM SHOPPING)