Complaint for Collection of Sum of Money COMPLAINT COMES NOW Plaintiff, by counsel and to this Honorable Court, respectfully

states that: 1. Plaintiff Juan Dela Cruz is of legal age, Filipino, single and a resident of Manila, Philippines. For purposes of this action, plaintiff may be served with all orders, notices, and other processes of this Honorable Court through the office address of the undersigned counsel indicated below; 2. Defendant Maria Mercedes of legal age, Filipino, single, and may be served with summons and other processes of this Honorable Court at his last known address at Makati, Philippines; 3. Sometime on June 2013, Defendant obtained from and was granted a loan accommodation by the Plaintiff in the principal amount of thirty thousand pesos (P30,000), Philippine Currency; 4. A true and faithful machine reproduction of the Promissory Note made by the Defendant on June 15, 2013 is hereto attached as Annex "A"; 5. As of November 25, 2013 Defendant still has an Outstanding Balance to Plaintiff amounting to thirty thousand pesos (P30,000), Philippine Currency, and has failed and neglected to pay, without just and valid grounds, the said Outstanding Balance for the aforementioned loan accommodation; 6. Despite Plaintiff's repeated demands, both written and verbal, Defendant failed, neglected and refused, and continues to fail and refuse to pay and to settle the said Outstanding Balance, without just and valid grounds, to the continued damage and prejudice of Plaintiff; 7. A true and faithful machine reproduction of the Plaintiff's demand letter to Defendant dated September 21, 2013 is hereto attached as Annex "B"; 8. Consequently, Plaintiff was constrained to engage the services of counsel to whom it obligated itself to pay as Attorney's Fees the amount equivalent to three thousand pesos (10%) percent of the total amount due from Defendant to Plaintiff.

PRAYER WHEREFORE, after due notice and hearing, Plaintiff respectfully prays that judgment be rendered against the Defendant as follows: 1. Ordering the Defendant to pay Plaintiff the sums of: a.) The amount of thirty thousand pesos (P30,000), representing Defendant's Outstanding Balance plus interest at the rate of six hundred pesos (2%) per month as stipulated upon in the Promissory Note; b.) Three thousand pesos (10%) percent of the total amount due as Attorney's Fees plus Appearance Fee at the rate of P100 per court hearing / conference; c.) Six thousand Pesos (20%) percent of the total amount due as Collection Charges / Liquidated Damages; d.) The costs of suit. 2. Plaintiff respectfully prays for such other reliefs as may be just and equitable in the premises.

SUBSCRIBED AND SWORN TO before me this 26th day of November, 2013 in Manila, Philippines. I hereby certify that the plaintiff has read and understood the contents thereof.

Mr. Juan Dela Cruz Plaintiff

Atty. Pedro Penduko Counsel for the Plaintiff

ANSWER WITH COUNTERCLAIMS

COMES NOW Defendant Maria Mercedes, by counsel and unto this Honorable Court, most respectfully states and avers that: 1. Defendant admits the allegations contained in paragraphs 1, 2, 3, and 4 of the Complaint; 2. Insofar as paragraph 5 is concerned, two installments were already made of P5,000 each and with a total of P10,000 therefore making the outstanding balance only amounting to twenty thousand pesos (P20,000). 3. Defendant vehemently denies the allegations contained in paragraphs 6 and 7 of the Complaint. Never was there any verbal nor written demand made. 4. Consequently, there is no such necessity for paragraph 8 of the Complaint that asserts the legal services of a counsel as the obligation is still deemed proper. 5. As a consequence of the malicious and wrongful filing of this entirely baseless and unjustified action, which is attended by extreme bad faith, lies and deception, and denial of payments made, the Defendant and her family had suffered sleepless nights, mental anguish, serious anxiety, severe stress, wounded feelings, besmirched reputation and social humiliation for which Plaintiff should be made liable for moral damages in the total amount of five thousand pesos (P5,000); 6. In instituting this unwarranted and clearly unfounded suit against the Defendant, Plaintiff had acted in a wanton, fraudulent, reckless and malevolent manner and, by way of example or correction for the public good, Plaintiff should be made liable to pay Defendant exemplary damages in the total amount of three thousand pesos (P3,000); 7. As a further consequence of the malicious and wrongful filing of the present action, Defendant was constrained to hire the services of counsel for a legal fee of two thousand pesos (P2,000), plus two hundred pesos (P200) per court appearance, and to incur expenses of litigation for which plaintiff should be made to pay.

PRAYER WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed that after hearing on the merits, this Honorable Court issue an Order: 1. Dismissing the Complaint in toto for utter lack of merit. 2. Granting moral damages in favor of the Defendant in the amount of five thousand pesos (P5,000); 3. Granting exemplary damages in favor of the Defendant in the amount of three thousand pesos (P3,000); 4. Granting defendant's claim for attorney's fees in the amount of two thousand pesos (P2,000) plus two hundred pesos (P200) per court appearance, and the amount of litigation expenses as may be proved during trial. Other reliefs just and equitable under the premises are likewise prayed for. Manila, Philippines, November 26, 2013.

Atty. James Yup Counsel for the Defendant Copy furnished to:

Atty. Pedro Penduko Opposing Counsel