Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch _______, Manila

JUNALHYN NIPOTNIPOT,
Plaintiff,

versus FOR: COLLECTION OF SUM OF

MONEY

RHENMARR BULALACAO,
Defendant,
x ----------------------------------x

COMPLAINT

COMES NOW, the plaintiff, by the undersigned counsel, and unto

this Honorable Court, respectfully alleges:

1. That plaintiff is of legal age, Filipino, married and a resident of

1975 Arambulo St., Tondo Manila;

2. That defendant is also of legal age, Filipino citizen and may be

served with summons and other processes of the Honorable Court
at 27 Arambulo Sto. Nino Meycauyan Bulacan or in his office
address 6/F The GG Building, San Andres Bukid, Manila;

3. That sometime on March 2016, Plaintiff was introduced to the

defendant by a charity volunteer and the defendant introduced
himself as the HR Assistant of The Gewd Guysh Co. in San Andres
Bukid, Manila;

4. That defendant asked the Plaintiff if he can loan money for himself
and for the other volunteers considering that their 13th month pay
was still in process;

5. Considering that Plaintiff has been doing Charitable Works and

Immersion Programs in various barangays namely: Brgy. Walang
Dulo, Brgy. Gitna Lang, Brgy. Medyo Dulo, and Brgy. Dulong Dulo,
the Plaintiff succumbed to the flowery words of the defendant and
relied on the fact that since the defendant was the HR Assistant of
a Charitable Institution, he will not ruin his reputation;

6. Thus, on March 4, 2016 the Plaintiff gave to the Defendant the

amount of P75,000 in his office and the Defendant promised to pay
the same one month after receipt, the money was received as
evidenced by the receipt (copy hereto attached and marked as
ANNEX A);

7. That there are other transactions made after the first transaction,
to wit;

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 a. Defendant received again the amount of P20,000 last March 17,
2016 in his office which the latter received as evidenced by the
receipt (copy hereto attached and marked as ANNEX B) and
defendant promised to pay the same one month thereafter;

b. Defendant received again the amount of P17,500 last April 9,

2016 in his office which the latter received as evidenced by the
receipt (copy hereto attached and marked as ANNEX C) and
defendant promised to pay the same one month thereafter;

8. That when the obligation became due, Plaintiff orally demanded

defendant to pay but the latter refused to do so;

9. That prior to the filing of this complaint written demand was made
to the Defendant which the latter duly received last May 12, 2016
(copy of the demand letter is hereto attached and marked as Annex
D);

10. That due to the unjust refusal of defendant to comply with

the demand, plaintiff was forced to engage the services of counsel
and paid Php 10,000.00 as attorneys fees and Php. 2,500 per
court appearance.

WHEREFORE PREMISES CONSIDERED, plaintiffs through

undersigned counsel, pray this Honorable Court, after due hearing, to
adjudge defendants, to pay the Plaintiff the Amount of P112,500.00 and
to pay Php. 10,000 as Attorneys fees:

Other remedies as may be just and equitable in the premises.

GERTRUDE MARIE MAE J. ARQUILLO

Counsel for Complainant
Roll No. 64345
PTR No. 4945627/ June 5, 2016/ Makati
IBP No.: 1014518 for June 14, 2016/ Makati Chapter
MCLE Compliance No. V-0014723
143 Yague St., Barangay Singkamas, Makati City

VERIFICATION AND CERTIFICATION

I, JUNALHYN NIPOTNIPOT , of legal age, Filipinos, with

address at 1975 Arambulo St., Tondo Manila, under oath, depose and
state:

That I am the Plaintiff in the above-entitled case; That I have

caused the preparation of the above Complaint and have read the same
and know the contents thereof; That the allegations contained therein

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are true and correct of my own personal knowledge, and based on
authentic records;

That I further certify that: (a) I have not theretofore commenced

any other action or proceeding or filed any claim involving the same
issues or matter in any court, tribunal, or quasi-judicial agency and, (b)
to the best of my knowledge, no such action or proceeding is pending
therein; (c) if I should thereafter learn that the same or similar action or
proceeding has been filed or is pending before the Supreme Court, the
Court of Appeals, or any other tribunal or quasi-judicial agency, I
undertake to report such fact within five (5) days there from to the court
or agency wherein the original pleading and sworn certification
contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set our hands this

________day of June 2016 at Manila Philippines.

JUNALHYN NIPOTNIPOT

SUBSCRIBED AND SWORN to before me, this _________day of

June 2016 by Affiant who appeared personally and exhibited her SSS
card bearing no. CRN 0111-0772201-5 as proof of her
identity.

Doc. No.________;
Page No.________;
Book No.________;
Series No. 2016

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