REPUBLIC OF THE PHIPIPPINES

First Judicial Region

Regional Trial Court
Baguio City, Branch___

Professor A, Civil case no. ___

Plaintiff,
For: Collection of
--versus-- sum of money

Doctor B,
Defendant,

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

COMPLAINT

With all due respect to this most honorable court, plaintiff through
the undersigned counsel, respectfully alleges that:
1. Plaintiff, Professor A, a professor of SLU Baguio City, and a
manager of lending company, is a resident of Purok 7, Bonifacio
St., Baguio City of legal age, Filipino and Single;

2. Defendant Doctor B, is a citizen of the Philipines, of legal age,

single and a resident of #321 Quezon Hill, Baguio City;

3. Professor A and Manager B entered a loan agreement in which

the former agreed to lend an amount of P1.5 million pesos;

4. The loan agreement had a term of 1 year with 10% interest per
annum;

5. As a payment thereof, Doctor B issued a postdated check and

when presented to the bank it was dishonored for insufficiency
of funds;
6. Professor A, sent a demand letter to Doctor B for him to make
good of the check but despite repeated demands he failed to do
so;

7. The failure of Doctor B to pay his obligation to Professor A

prompted the latter to avail the services of a counsel to defend
and protect his right.

PRAYER
Wherefore, we humbly ask this honorable court to hear and
decide the case in favor of the plaintiff and after due hearing and
legal processes, to order the defendant to comply with the
following:
1. To pay the amount of P 1,500,000.00 related to unpaid loan
obligation with 10% interest counted from the first demand;
2. To order the defendant to pay moral damages for the emotional
distress he cause to the plaintiff when he did not make good of
his commitments;
3. To order the corporation to pay the cost of litigation including
attorney’s fees; and,
4. All other reliefs that the court may deem reasonable and
necessary.

Baguio City, Philippines, this 18th day of August 2018.

ATTY. FHYNN P. SAN JOSE

Roll No. 5551: 03-02-10
IBP Lifetime: 3356
MCLE Compliance: II 12345
PTR No. 86710
 VERIFICATION AND CERTIFICATION AGAINST
FORUM SHOPPING

I, plaintiff, Professor A, of legal age, Filipino, single and a

resident of Purok 7, Bonifacio St., Baguio City, having been duly
sworn to in accordance with law hereby depose and state that:

1. I have caused the preparation and filing of the foregoing

complaint;
2. I have read the contents thereof and all allegations therein
are true and correct to the best of my own personal
knowledge;
3. I hereby certify that I have not commenced any other action
or proceedings involving the same issues and parties in any
court or tribunal within the Philippines and that to the best
of my knowledge and belief, no such other action or
proceeding is pending before any court, and if I should
thereafter learn of similar action before any court, I will
promptly inform the court within 5 days from knowledge
thereof.

In witness whereof, I have hereunto affixed my signature this

18th day of August, 2018, in the City of Baguio, Philippines.

Mr. Professor A
247 G- Pintas 10, La Trinidad
Benguet Philippines
Driver’s License PB2-09-223344
 Subscribed and sworn before me, this 18th day of August, 2018,
Baguio Philippines, affiant Pete Batongbuhay exhibiting to me his
Driver’s License PB2-09-223344, as proof of his identity.

Doc. No. 22 Atty. Expert Counsel

Page No. 42 Roll No. 5551: 03-02-10
Book No. 92 IBP Lifetime: 3356
Series of 2018 MCLE Compliance: II 12345
PTR No. 86710

ATTY. LADY LYNE R. SALES

Notary Public
Roll No.23153-02-07-06
IBP Lifetime: 38673
MCLE Compliance: IV 1234
PTR No. 886622