Republic of the Philippines

National Capital Judicial Region

RTC, Branch 123
Caloocan City

JOY SALVA
Plaintiff,

-versus- Civil Case No. 12345

For: Collection of sum of money
LOLITA SY
Defendant.

x-------------------------x

COMPLAINT

Plaintiff by counsel respectfully states that:

1. Plaintiff Joy Salva, Filipino, of legal age, single, and with residence at 1234 1st Ave. St.,
Caloocan City;

2. Defendant Lolita Sy, Filipino, of legal age, single, residing at 123 San Miguel St., Manila
City;

3. On September 9, 2017, Defendant borrowed money from the Plaintiff the amount of
P600,000.00 with 5% monthly interest, as evidenced by the Loan Agreement. (A copy of
the Loan Agreement is attached as Annex “A”).

4. The Loan Agreement provides that Defendant shall pay the amount of P130, 000.00 every
end of the month inclusive of the 5% monthly interest for the next Six (6) months starting
October 9, 2017 until April 9, 2018. The Loan Agreement further provides that failure to
pay a monthly installment shall make the remaining balance to be due and demandable
after legal demand by the Plaintiff.

5. Defendant on December 9, 2018, failed to pay his monthly due to the Plaintiff, hence the
balance of P520, 000.00 became due and demandable.

6. Despite receipt of repeated demands, Defendant still failed to pay the Plaintiff as
evidenced by the Demand Letters. The copy of the Demand Letters are herein attached as
annex “B and C”

7. Plaintiff was forced to institute this complaint based on Article 1169 of the Civil Code
which provides that:
 “Those obliged to deliver or to do something incur in delay from the time the obligee
judicially or extrajudicially demand from them the fulfillment of their obligation. xxx”

PRAYER

WHEREFORE, Plaintiff respectfully prays that this Honorable Court, orders the
Defendant to pay the plaintiff the remaining balance of Php520,000.00.

Other reliefs just and equitable under the law are likewise prayed for.

9 February 2018, in the City of Caloocan.

ATTY. JUAN DELA CRUZ

Counsel for the Plaintiff
101 XXX St., Caloocan City
(02) 444-000
Roll of Attorney No. 10101
IBP No. 4080255 / June 2014. Caloocan City.
PTR No. 9833997 / June 2014. Caloocan City.
MCLE Certificate of Compliance No. 14344

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, JOY SALVA, of legal age, Filipino, single, and a resident of 123 1st Ave. St., Caloocan City,
after having been sworn in accordance with law, depose and state that:

1. I am the Plaintiff in the above-entitled Complaint;

2. I have caused the preparation of the foregoing Complaint and understood the contents thereof;

3. I hereby declare that all the allegations contained therein are true and correct according to my
knowledge and belief; and/or on the basis of copies of documents and records in my possession;

4. I have not commenced any other action or proceeding involving the same issue in the Supreme
Court, the Court of Appeals, or any other quasi-judicial tribunal or agency;

5. To the best of my knowledge, there is no other pending action or proceeding of the same
nature before any court, tribunal, or quasi-judicial agency;

6. Should I thereafter learned that a similar action or proceeding has been filed or is pending
before the Supreme Court, the Court of Appeals, or any other quasi-judicial tribunal or agency, I
undertake to report such fact to the court within five (5) days from discovery.
IN WITNESS WHEREOF, I have hereunto set my hand this 9th day of February 2018 in
Caloocan City, Philippines.

JOY SALVA
Plaintiff

SUBSCRIBED AND SWORN to before me this 9th day of February 2018, in Caloocan City,
Philippines, by Joy Salva who exhibited to me his Driver’s License No. 12345, issued on
September 26, 2014 at Quezon City, as competent evidence of his identity.

Doc. No. 01; ATTY. MANUEL DAIRIT

Page No. 02; Notary Public Commission
Book No. III; Serial No. 02241993 Until 12/31/20
Series of 2018. Roll of Attorney No. 201078517/
` June 2014. Caloocan City.
PTR No. 20140457 / June 2014.
Caloocan City.
MCLE Certificate of Compliance
No. 10101