REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT Branch __, Catanduanes Maria Delos Reyes, Plaintiff, - versus Juan

Dela Cruz, Respondent. x ----------------------------------------------- x Criminal Case No. __________ For: Collection of sum of money

COMPLAINT Complainant, through undersigned counsel and to this Honorable Court, respectfully avers that: 1. Complainant Maria Delos Reyes is of legal age, single, Filipino and with residence at #13 Deborah Street, Eastern Cavinitan Virac, Catanduanes while respondent Juan Dela Cruz is also of legal age, single, and with residence at Lot 4, Block 6, Phase 1, Mahogany Place, Calatagan Virac, Catanduanes where he may be served with summons and other legal processes. 2. On January 20, 2012, respondent borrowed four hundred thousand pesos (P400,000.00) payable within three months from the date mentioned but not later than April 20, 2012, as evidenced by a promissory note, which he executed and which provides: "I, JUAN DELA CRUZ, promise to pay to MARIA DELOS REYES or to her order, the total sum of two hundred fifty thousand pesos (P250,000.00) within three months from this date---but not later than January 20, 2012--- at her residence or place of business. In case of my failure to pay, the amount or remainder thereof, it shall incur 1% interest per month until paid." Virac,Catanduanes, October 20, 2011 (SGD) JUAN DELA CRUZ

True copy of said promissory note is attached hereto and made an integral part hereof as Annex "A". 3. The due date, April 20, 2012, of said promissory note (Annex "A") arrived yet respondent failed to pay the said amount of P400,000.00, in breach thereof. 4. As a result, complainant with the assistance of her counsel wrote a demand letter dated April 25, 2012 (attached hereto as Annex "B") asking for the payment of the entire obligation of P400,000.00 within seven (7) days upon its receipt.

5. Notwithstanding demands, both verbal and written, made upon respondent, the latter failed and refused and continues to refuse to pay his lawful obligation. 6. Thus, complainant by counsel was constrained to file the present complaint after complainant and respondent was not able to reach an amicable settlement during the Barangay Proceeding. PRAYER Wherefore, complainant respectfully prays that judgment be rendered finding respondent guilty and ordering him to pay complainant the entire debt of four hundred thousand pesos (P400,000.00), with penalty interest of 1% per month from May 6, 2012 until paid. Complainant further prays for such other reliefs as may be just and equitable in the premises. Virac Catanduanes, June 25, 2012.

ATTY. JOSEPHINE D. ROJAS Counsel for the Plaintiff Roll No. 123456 PTR No. 61879; 2/2/1986; Manila IBP No. 12345; 1/3/1986; Manila MCLE Compliance No. 54321

VERIFICATION AND CERTIFICATION OF NON FORUM SHOPPING I, Maria Delos Reyes is of legal age, single, Filipino and with residence at #13 Deborah Street Eastern Cavinitan Virac, Catanduanes subscribing under oath, hereby deposes and states that: 1. 2. 3. I am the complainant in the instant case; I have read foregoing Complaint and the allegations therein are true and correct of my I attest to the authenticity of the annexes thereof; 4. I have not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency;

own knowledge and/or based on authentic records on hand;

5. No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency; 6. If I should learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency, I hereby undertake to notify this Honorable Court within five (5) days from such notice. WITNESS MY HAND this 25th day of June 2012 at Virac, Catanduanes, Philippines.

Maria Delos Reyes Affiant SUBSCRIBED AND SWORN to before me, a notary public, this 25th day of June 2012 inVirac, Catanduanes, affiant MARIA DELOS REYES, exhibiting to me her Community Tax Certificate No. 12346 issued at Virac, Catanduanes on January 4, 2011.

ATTY. DESMOND STONE Notary Public Roll No. 23456 PTR No. 71899; 2/2/1989; Manila IBP No. 12345; 1/3/1989; Manila MCLE Compliance No. 67899