REPUBLIC OF THE PHILIPPINES

Province of Surigao del Norte

City/Municipality of Surigao
MUNICIPAL TRIAL COURT
Branch 01, City of Surigao

Hercules Ramirez,
Plaintiff,
CIVIL CASE No. 123456
FOR : SUM OF MONEY

-versus-

Cupid Hedalgo,
Defendant,
x-----------------------x

COMPLAINT

Plaintiff, by counsel, and unto this Honorable Court:

The Parties
1. The plaintiff Hercules Ramirez is of legal age, Filipino citizen, a resident
of 10348 Cross Village, Barangay Luna, Surigao City;
2. The defendant, Cupid Hedalgo, is also of legal age, Filipino citizen and
a resident of 2323 Bernadette Village, Barangay Luna, Surigao City where
he may be served with summons;
The Facts
3. That, on 23 March 2013 defendant obtained a loan from plaintiff the
sum of one hundred twenty thousand pesos ( 120,000.00) payable within
120 days from date of receipt at 12% per annum;
4. That said loan, now overdue, is evidenced by a promissory note signed
by the defendant a copy of which hereto attached as Annex A and made
part of the complaint;
5. That despite repeated demands, both written is and oral, defendant has
failed and refused to pay the said loan. A copy of the demand letters of
which hereto attached as Annex B and made part of the complaint;
6. That the resort to the Barangay Conciliation process proved fruitless as
defendant failed to appear despite notice to appear. Thus, a Certification

to File Action, a copy of which is attached as Annex C and made part of

this complaint, was issued by the Barangay Chairman;
7. That due to the unjust and unlawful act of the defendant to comply with
the said demands, the plaintiff was compelled to institute this action
engaging of counsel amounting to 30,000.00
PRAYER
WHEREFORE, it is respectfully prayed that judgement be rendered
against defendant to pay the plaintiff the sum of 120,000.00 plus interest
of 12% from the date of the instrument until full amount is paid and
attorneys fees and costs of the suit.
Other equitable reliefs are likewise prayed for.
28th of August, 2014, Surigao City

ANALEE ALVERASTINE
Counsel for Plaintiff
3rd floor, Yuipco Bldg.
Borromeo Street, Surigao City
Attorneys Roll no. 12345
IBP No.23456-01/08/11-Surigao
PTR No. 45678-01/08/11-Surigao
MCLE Compliance No.II-0008776-Nov 18, 2013

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, Hercules Ramirez, of legal age, after having been duly sworn, depose
and state that:
1. I am the Plaintiff in the foregoing Complaint for Sum of Money.
2. I caused the preparation of the Complaint, which I have fully read and
understood.
3. I hereby affirm that all factual allegations contained in said Complaint
are true and correct of my own personal knowledge and belief, as well as
true and correct on the basis of authentic documents and records in my
possession.
4. I certify that I have not heretofore commenced any action or filed any
claim involving the same issues in any court, tribunal, or quasi-judicial
agency.
5. If I should hereafter learn that any other similar action or claim has been
filed or is pending, I shall report that fact within five (5) days from
knowledge thereof to this Honorable Court.

HERCULES RAMIREZ
CTC No.:01-55454543- 1
Issued on: February 17, 2013
Issued at: Surigao City

SUBSCRIBED AND SWORN to before me this 28th day of August 2014, at

Surigao City, Surigao del Norte

ANALEE ALVERASTINE
Counsel for Plaintiff
3rd floor, Yuipco Bldg.
Borromeo Street, Surigao City
Attorneys Roll no. 12345
IBP No.23456-01/08/11-Surigao
PTR No. 45678-01/08/11-Surigao
MCLE Compliance No.II-0008776-Nov 18, 2013