Republic of the Philippines

NATIONAL CAPITAL REGION

Regional Trial Court
Branch _____
Quezon City

JOSEFINA RAMOS, Civil Case No. _____________

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

MARIE CARLOS,
Defendant
x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court,

hereby respectfully avers:

1. That plaintiff JOSEFINA RAMOS is of legal age, Filipino,

married to ALBERTO RAMOS, and a resident of 1598 Scout Fuentebella,
Timog, Quezon City, Philippines while the defendant DR. MARIE
CARLOS is also of legal age, married to DIEGO CARLOS, Filipino and a
resident of 689 Brentwood Street, Brookside Hills, Cainta, Rizal, Philippines
where summons and court processes may be served;

2. That on January 15, 2018, the defendant borrowed from the

plaintiff a sum of money amounting to Eight Hundred Thousand Pesos
(Php800,000) with an agreed interest of fifteen percent (15%) per annum as
evidenced by a promissory note herein attached as Annex “A” and form an
integral part of this complaint;

3. That as shown in the attached promissory note, the indebtedness of

the defendant has become due and demandable on January 15, 2019;

4. That despite plaintiff's repeated demands, both written and verbal,

defendant failed, neglected and refused to fulfill obligations without just and
valid grounds to the continued damage and prejudice of plaintiff, as
evidenced by Annex “B” – Demand Letters;

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

entitled to the payment of the entire amount of Eight Hundred Thousand
Pesos (Php800,000.00) plus legal interest.
 6. 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 One
Hundred Thousand Pesos (Php 100,000.00) and an appearance fee of Two
Thousand Pesos (Php 2,000.00) per hearing as evidenced by Annex “C” –
Contract for Legal Services;

7. That the plaintiff has paid for litigation expenses amounting to

Twenty Thousand Pesos (Php 20,000.00) as evidenced by Annex “D” –
Official Receipt;

8. 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 One Million Pesos (Php 1,000,000.00) plus legal

interest as Actual Damages at the rate of five percent (5%) per
month as stipulated in the promissory note;

b. Moral Damages, Exemplary Damages at the sum discretion of the

court;

c. Attorney’s Fees amounting to One Hundred Thousand Pesos (Php

100,000.00) and an appearance fee of Two Thousand Pesos (Php
2,000.00) per hearing

d. Litigation Expenses amounting to Twenty Thousand Pesos (Php

20,000.00).

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

Quezon City, 21 August, 2019.

ATTY. ALFONSO MIGUEL V. DIMLA

Counsel for Petitioner
Dimla & Pobe Law Office, Valero Street, Makati City
Roll of Attorneys No. 98753
PTR NO. 654321, 01/06/14, Makati City
IBP NO. 123456, 01/04/14, Makati City
MCLE Comp. No. IV-0009876, 01/02/19
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF QUEZON CITY ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, JOSEFINA RAMOS, of legal age, Filipino, married to

ALBERTO RAMOS, and a resident of 1598 Scout Fuentebella, Timog,
Quezon 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 19th

day of August 2019 at Makati City, Philippines.

JOSEFINA RAMOS
Affiant
TIN 98765-003; Quezon City
 SUBSCRIBED AND SWORN to before me, this 15th day of August
2019, affiant exhibiting to me his Tax Identification Card as shown above
below his name as competent evidence of his identity.

ATTY. ALFONSO MIGUEL V. DIMLA

Counsel for Petitioner
Dimla & Pobe Law Office, Valero Street, Makati City
Roll of Attorneys No. 98753
PTR NO. 654321, 01/06/14, Makati City
IBP NO. 123456, 01/04/14, Makati City
MCLE Comp. No. IV-0009876, 01/02/19

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2019;
 ANNEX A

Promissory Note