FORM NO.

4: COMPLAINT FOR SUM OF MONEY: PLAINTIFF AS NATURAL

PERSON

Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 101, Makati City

ESTA PADORA,
Plaintiff,

Civil Case No. 000882

- versus –
For: Sum of Money

MANGGA GANTSO,
Defendant.
x -------------------------- x

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes

Park, Makati City; defendant is also a Filipino, of legal age and resident of
6752, Forbes Park, Makati City, where he may be served with summons and
other processes.

2. Sometime in January 2005 and over a period of six (6) months,

defendant borrowed certain amounts from plaintiff. Defendant promised
to pay these amounts on an installment basis monthly. These amounts now
total Nine Hundred Thousand Pesos (P900,000.00).

3. Despite repeated demands, both oral and written, defendant

failed or has refused to pay any amount to plaintiff as no installment
payment has even been made. A copy each of plaintiff’s two (2) demand
letters is attached as ANNEX A and B.

4. 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 C, was
issued by the Barangay Chairman.
 5. Defendant’s obligation is due and demandable and plaintiff is
entitled to the payment of the entire amount of Nine Hundred Thousand
Pesos (P900,000.00) plus legal interest.
6. By reason of defendant’s 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 Fifty Thousand Pesos (P50,000.00).

WHEREFORE, plaintiff respectfully prays for judgment in his favor

through a Decision directing defendant to pay him NINE HUNDRED
THOUSAND PESOS (P900,000.00), with legal interest, as ACTUAL DAMAGES
and FIFTY THOUSAND PESOS (P50,000.00) as Attorney’s Fees.

Other just and equitable reliefs are also prayed for.

Quezon City for Makati; 13 April 2007.

(Sgd.) ATTICUS FINCH

Counsel for Plaintiff
[Address]
FORM NO. 4: COMPLAINT FOR SUM OF MONEY: DEFENDANT AS JURIDICAL
PERSON

Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 101, Makati City

ESTAFA DAMAGA,
Plaintiff,

Civil Case No. 000883

- versus –
For: Sum of Money

LIWANAG CORPORATION,
Defendant.
x -------------------------- x

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes

Park, Makati City; defendant is also a Filipino, of legal age and resident of
6752, Forbes Park, Makati City, where he may be served with summons and
other processes.

2. Sometime in January 2005 and over a period of six (6) months,

defendant, a corporation duly organized under the laws of the Philippines,
borrowed certain amounts from plaintiff through its president Antonio
Liwanag. Defendant promised to pay these amounts on an installment basis
monthly. These amounts now total Nine Hundred Thousand Pesos
(P900,000.00).

3. Despite repeated demands, both oral and written, defendant

failed or has refused to pay any amount to plaintiff as no installment
payment has even been made. A copy each of plaintiff’s two (2) demand
letters is attached as ANNEX A and B.

4. 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 C, was
issued by the Barangay Chairman.
 5. Defendant’s obligation is due and demandable and plaintiff is
entitled to the payment of the entire amount of Nine Hundred Thousand
Pesos (P900,000.00) plus legal interest.

6. By reason of defendant’s 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 Fifty Thousand Pesos (P50,000.00).

WHEREFORE, plaintiff respectfully prays for judgment in his favor

through a Decision directing defendant to pay him NINE HUNDRED
THOUSAND PESOS (P900,000.00), with legal interest, as ACTUAL DAMAGES
and FIFTY THOUSAND PESOS (P50,000.00) as Attorney’s Fees.

Other just and equitable reliefs are also prayed for.

Quezon City for Makati; 13 April 2007.

(Sgd.) ATTICUS FINCH

Counsel for Plaintiff
[Address]
FORM NO. 5: JURIDICAL PERSON AS PARTIES: REPUBLIC OF THE PHILIPPINES
AS PARTY

Republic of the Philippines, thru

The Department of Health,
Plaintiff,

-versus- Civil Case No.

ABC Construction Co., Inc.,

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

FORM NO. 5: JURIDICAL PERSON AS PARTIES: PRIVATE CORPORATION OR

OTHER JURIDICAL ENTITIES DULY REGISTERED, AS PARTIES.

XYZ Company, Inc.,

Plaintiff,

-versus- Civil Case No.

Juan De la Cruz,
Defendant.
x---------------------------------------x

Allegations showing it is a juridical entity:

Plaintiff XYZ Company, Inc., is a corporation duly organized and

existing under and by virtue of the laws of the Philippines, with principal
offices at 1234 Ayala Ave., Makati City, where it may be served with
summons and other legal processes.

FORM NO. 6: CORPORATION DE FACTO AS PLAINTIFF.

XYZ Corporation,
Plaintiff,

-versus- Civil Case No.

David Fermosa,
Defendant.
x-------------------------------------x

Plaintiff XYZ Company, Inc., is a corporation with principal offices at

1234 Ayala Ave., Makati City, where it may be served with summons and
other legal processes (keeping silent as to the fact that the plaintiff
corporation was not duly-registered as a corporation because the rule is
that where a corporation, not registered, is suing a third person on a
contract the latter entered into with it, he may not be heard to dispute the
existence of said corporation, as he is stopped from denying the corporate
existence) ;

Allege cause of action…

FORM NO. 5: CORPORATION DE FACTO AS DEFENDANT.

ESTAFA DAMAGA,
Plaintiff,

Civil Case No. 000883

- versus –
For: Sum of Money

LIWANAG CORPORATION AND ANTONIO LIWANAG,

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

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes

Park, Makati City; defendant is also a Filipino, of legal age and resident of
6752, Forbes Park, Makati City, where he may be served with summons and
other processes.

2. Sometime in January 2005 and over a period of six (6) months,

defendant, a corporation, through its president Antonio Liwanag, borrowed
certain amounts from plaintiff through its president Antonio Liwanag.
Defendant promised to pay these amounts on an installment basis monthly.
These amounts now total Nine Hundred Thousand Pesos (P900,000.00).

3. Despite repeated demands, both oral and written, defendant, said

corporation has refused to pay any amount to plaintiff, as no installment
payment has even been made, alleging that it was not liable as it did not
register itself as a corporation. A copy each of plaintiff’s two (2) demand
letters is attached as ANNEX A and B.

4. Investigation shows that the persons who claimed to be president

of said corporation who were also the same person dealing with the
plaintiff in connection with the loan and who represented that the
defendant Liwanag Corporation was duly registered with the Securities and
Exchange Commission, when in fact it was not.

5. Defendant’s obligation is due and demandable and plaintiff is

entitled to the payment of the entire amount of Nine Hundred Thousand
Pesos (P900,000.00) plus legal interest.

6. By reason of defendant’s 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 Fifty Thousand Pesos (P50,000.00).

WHEREFORE, plaintiff respectfully prays for judgment in his favor

through a Decision directing defendant to pay him NINE HUNDRED
THOUSAND PESOS (P900,000.00), with legal interest, as ACTUAL DAMAGES
and FIFTY THOUSAND PESOS (P50,000.00) as Attorney’s Fees.

Other just and equitable reliefs are also prayed for.

Quezon City for Makati; 13 April 2007.

(Sgd.) ATTICUS FINCH

Counsel for Plaintiff
[Address]