FORM NO. 64. Complaint for a sum of money. Republic of the Philippines Regional Trial Court, Branch 40, Quezon City JUAN CRUZ Plaintiff, -versus- Civil Case No. 2345 For a sum of money JOSE MANZANO, Defendant. x-- nose x COMPLAINT je Court, Plaintiff, by undersigned counsel and to this Honorab! respectfully states: resi- 1, Plaintiff Juan Cruz is of legal age, married, and Manzano dence at 60 Mayon St., Quezon City, while defendant 20" aicon St; is also of legal age, married, and with residence ay ind other legal Quezon City, where he may be served with summon processes. ‘ wr On March 23, 2004, defendant borrowe™ on at 12% per sos (Pi,005-000.00) from plaintiff, with interes’ beget: enced BY & sewnum’ payable on or before March 23. 200° ogee: promissory note, which he executed and whi P'1,000,000.00. cmunat Juan Cruz efor value received, Thereby promise 10 PATTI of One io renters at 60 Mayon St. Quezon ONY: 0° ioe per an- is residence ¢500.00) with interest thereon £7 'y 5 2008. Million (P1000 123, 2004, payable on or before Wt lated Se ne T fail to pay said amount, including its stip in y rg fees and expenses of oH e to pay him, as attorney's : iereato, | Aes af Two Hine pesos (P200,000-00) (Signed) Jose Manzano Borrower ‘True copy of said promissory, note is attached hereto and made an integral part hereof as Annex “AL 3, The due date, March 23, 2005, of said promissory note (Annex “A") arrived, and yet defendant failed to pay the said amount of P1,000,000.00, in breach thereof. 4. Notwithstanding demands, both verbal and written, made upon defendant, the latter failed and refused and continues to refuse to pay his lawful obligation. 5. Asa result of defendant's breach of obligation to pay his indebtedness, as well as the stipulated interests thereon, plaintiff was constrained to secure the services of counsel to protect his inter-VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING J f,duan Cruz, of legal age and with residence at 60 Mayon St. Quezon City, after having been duly sworn, depose and say: J, ‘That {am the plaintiff in the above entitled complaint; 2, That J have caused the preparation of said complaint/ petition; 3, ‘That I have read the allegations therein contained, and that the same are true and correct of my personal knowledge and/or baned on authentic records. ‘That [ have not theretofore commenced any action or filed any claim involving the same issues in any court, tribunal, or quasi- judicial agency and, to the best of his knowledge, no such tive ‘action or claim is pending therein; (except the following: [here make ticomplete statement of the pending case, its basic issue, its present satus thereof); and if I should thereafter learn that the same or finilar action or claim has been filed or is pending, I shall report that fact within five (5) days therefrom to the court wherein the aforesaid complaint or initiatory pleading has been filed, Witness my hand this 23rd day of March 2006 at Quezon Philippines City, JUAN CRUZ Affiant FORM NO. 13. Jurat. SUBSCRIBED AND SWORN to before me, a notary public in and for _,thisdayof____,at___, Philippines, affiant appearing before me with his CTC No.______ issued on = Mca and presenting to me a document. entitled —__ , affiant being known to me personally as he is a friend, acquaintance, town mate. e i known to notary public personally, the affiant is identified bs oe hotary public through his officially issued identity card or certificate or eure bearing his photograph and signature, such as Pass or SSS identity card, driver's license, ete.), and who sirmed est and to file the complaint and to incur attorney's fees and ex- penses of litigation, in the amount of P200,000, which should be assessed against defendant. WHEREFORE, plaintiff respectfully prays that judgment be rendered ordering defendant to pay plaintiff the amount of P1,000,000,00, with interests thereon at 12% per annum starting March 23, 2004 until fully paid, as well as the sum of P200,000.00 as and for attorney’s fees and expenses of litigation, plus costs. Plaintiff further prays for such other reliefs as may be just and equitable in the premises. Quezon City, May 20, 2005. Counsel. Form No. 8 JUAN DELA CRUZ ‘Counsel for. Address: Roll No. IBP No. on at * PTR No. on at