Republic of the Philippines

6TH JUDICIAL REGION

Regional Trial Court
Branch 6
Bacolod City

JOE TURKO, Civil Case No. _____________

Plaintiff FOR: COLLECTION FOR A SUM OF
MONEY
- versus -

FELICIANO GASTADOR,
Defendant
x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court, hereby
respectfully avers:

1. That plaintiff is of legal age, Filipino, single, and a resident of Alta Tierra
Village, Bacolod City, Philippines while the defendant is also of legal age, single,
Filipino and a resident of Brgy. Mansilingan, Bacolod City, Philippines where summons
and court processes may be served;

2. That on February 13, 2018, the defendant borrowed from the plaintiff a sum of
money amounting to Fifty Thousand Pesos (P50,000.00) the same to be paid within 30
days from the said date, as evidenced by a promissory note herein attached as Annex “A”
and form an integral part of this complaint;

3. The indebtedness of the defendant has become due and demandable on

February 13, 2018;

4. That despite plaintiff's oral demands, defendant failed, neglected and refused to
fulfill obligations on the ground that among others the defendant has already paid the said
amount to the wife of plaintiff;

5. That the plaintiff in order to collect the debt which is already due, upon
presentment of the check with the drawee bank, the same check was found to have been
drawn against a closed account;

7. That the plaintiff has suffered moral damages at the sum discretion of the
Honorable Court;

WHEREFORE, premises considered, it is hereby respectfully prayed before the

Honorable Court to render decision in favor of the plaintiff and order the defendant to pay
the following:

a. the sum of Fifty Thousand Pesos (P50,000.00) as stipulated in the promissory

note;

Other reliefs and remedies deemed just and equitable under the foregoing
premises are likewise prayed for.
Bacolod, April 1, 2018.

ATTY. VINCENT ENRIQUE A. LUMPIA

My Commission No. is 58
Expires on December 31, 2015
Lumpia Law Office, Alta Tierra Village, Bacolod City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Bacolod City
IBP NO. 123456, 01/04/14, Bacolod City
MCLE Comp. No. IV-1234567, 01/02/14
REPUBLIC OF THE PHILIPPINES)
CITY OF BACOLOD ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, JOE TURKO, of legal age, Filipino, single, and a resident of Alta Tierra
Village, Bacolod City, Philippines, after being sworn in accordance with law, hereby
depose and say:

(1) That I am the Plaintiff in the above-entitled case;

(2) That I have caused the preparation of the above Complaint and I have read the
same and understood the contents thereof;

(3) That the allegations contained therein are true and correct of my own personal
knowledge and based on authentic records.

(4) That I further certify that: 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, to the best of my knowledge, no such action
or proceeding is pending therein; 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 therefrom to the court or agency wherein the original
pleading and sworn certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 6th day of April
2018, Bacolod City, Philippines.

JOE TURKO
Affiant
TIN 98765-003; Bacolod City

SUBSCRIBED AND SWORN to before me, this 1st day of April 2018, affiant
exhibiting to me his Tax Identification Card as shown above below his name as
competent evidence of his identity.

ATTY. VINCENT ENRIQUE A. LUMPIA

My Commission No. is 58
Expires on December 31, 2015
Lumpia Law Office, Alta Tierra Village, Bacolod City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Bacolod City
IBP NO. 123456, 01/04/14, Bacolod City
MCLE Comp. No. IV-1234567, 01/02/14

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2014;