Checklist for Complaint for Sum of Money

I. Title/Heading
II. Caption
III. Body (Plaintiff, through the undersigned counsel unto this Honorable Court, respectfully
avers:…)
1. Personal circumstances of plaintiff and defendant (name, of legal age, single/married,
citizenship, address);
2. That the defendant incurred a monetary obligation with plaintiff as creditor; state
circumstances giving rise to such obligation;
3. That the obligation has become due and demandable;
4. That plaintiff’s repeated despite demands, both written and verbal, the defendant failed,
neglected and refused to fulfill his obligations without just and valid grounds to the
continued damage and prejudice of plaintiff;
5. That the plaintiff, in order to enforce his rights and interests, has sought the services of a
legal counsel with attorney’s fees amounting to xxx and an appearance fee of xxx per
hearing;
6. That the plaintiff has paid for litigation expenses amounting to xxx;
7. That the plaintiff has suffered from mental anguish and serious anxiety as a result of
defendant’s acts, warranting the award of moral damages;
IV. Prayer (WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court
that judgement be rendered in favor of the plaintiff and that after judgement:…)
a. The defendant shall be ordered to pay the sum of money;
b. The defendant shall be ordered to pay attorney’s fees;
c. The defendant shall be ordered to pay moral damages.

(Such other reliefs and remedies under the premises are likewise prayed for.)

(xxx, Philippines, this xxx day of xxx, 2018)

(signed: Counsel for the Plaintiff)

V. Verification and Certification of Non-Forum Shopping