Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Pasay City, Branch ____

Complainant,

-versus- Civil Case No.

____________
For: Collection of Sum Money
and Damages.

Respondents.
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COMPLAINT

Plaintiff, by counsel, and for causes of action, respectfully states:

1.01 a corporation duly organized and registered under the laws of

the Republic of the Philippines with principal office address at
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2.01 Respondent
3.01 WCCC is engaged in the business of importation, sale and
distribution of kitchenware, glassware, household utensils, as well as hotel
and restaurant supplies while respondent HBLM is engaged in the business
of creating loyalty programs and loyalty solutions for its clients. HBLM is a
client/customer of WCCC.

4.01 From 18 January 2012 up to 02 March 2016 OS

(Php869,054.45) to respondent HBLM, this transactions are duly covered by
invoice receipts; and from 01 January 2014 up to 10 November 2016 WCCC
delivered items worth FOUR HUNDRED NINETEEN THOUSAND
SEVEN HUNDRED PESOS, this transactions are duly covered by delivery
receipts. However, out of the above-mentioned transactions 5.01.1
Attached and made an integral part of this complaint as its Annexes
“C” and “D” are machine copies of the Statement of Account from 01
January 2012 up to 04 June 2016 and from 01 January 2012 up to 04 June
2016 detailing the invoice number, date of delivery, and amount balance.

5.01 On 19 March 2016 WCCC sent HBLM a demand letter dated

17 March 2016 which was duly received by HBLM, reminding HBLM of
their outstanding obligation.

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 6.01.1 Attached and made an integral part of this
complaint as its Annex “E” is a machine copy of the demand
letter dated 17 March 2016.

6.01 Despite diligent efforts both verbally and in writing, HBLM

unjustifiably refused and failed to pay its just, valid, outstanding and
overdue obligation, to the damage and prejudice of WCCC.

7.01 If only to avoid rigors of litigation, WCCC instructed counsel to

make upon HBLM demand for payment. On several occasions counsel
attempted to serve personally, through private courier and registered mail
copies of the demand letter to HBLM. However, HBLM made it appear that
they are no longer doing business at their given address.

8.01 It was only on 10 January 2017 when a meeting with Mr. Co at

his office address at Unit 2401 West Tower, Philippine Stock Exchange
Center, Ortigas Center, Pasig City that counsel was able to personally serve
HBLM a demand letter.

8.01.1 Attached and made an integral part of this

complaint as its Annex “N” is a copy of the demand letter dated
12 January 2017 received by HBLM’s Accounting Manager.

9.01 Notwithstanding receipt of these demands, HBLM continues to

ignore and refuse to pay its outstanding and overdue obligation.

10.01 Due to HBLM’s deceitful acts and bad faith, WCCC was
constrained to file the instant case. HBLM should be made to pay, aside
from the principal amounts it owes, interests, damages, attorney’s fees and
costs of suit. As such, this Honorable Court should require HBLM to pay
Php200,000.00 for and as attorney’s fees and costs of litigation and such
other amount that may be proven during trial.

PRAYER
WHEREFORE, it is most respectfully prayed that the
Honorable Court, after due notice and hearing, render judgment:

(1)

by:

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