Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
City of Manila
Branch ____
LEGASPI TOWERS 300 INC.
represented by JESSIE JOHN
P. GIMENEZ,
Plaintiff,
- versus -

CIVIL CASE NO. __________

For: Sum of Money

SONJA RODRIGUEZ,
Defendant.
x------------------------------------------x

COMPLAINT
COMES NOW Plaintiff, by counsel, unto this Honorable Court,
most respectfully states that:
1. Plaintiff is a condominium corporation duly organized and existing
under the laws of the Philippines, having its principal office at
2600 Roxas Blvd., corner Pablo Ocampo (formerly Vito Cruz)
Street, Malate, Manila;
2. Defendant is Sonja Rodriguez, married, of legal age, Filipino,
whose last known address is at the 5 th floor, Unit H and I, 2600
Roxas Blvd., corner Pablo Ocampo (formerly Vito Cruz) Street,
Malate, Manila;
3. In the period of December 2008 to May 2015, the defendant
defaulted in paying Association Dues, Electric and Water bills to
the plaintiff totaling to Nine Hundred Twenty Six Thousand Two
Hundred Sixty Nine & 93/100 Philippine Currency (PHP
926,269.93), inclusive of a 2.5% penalty on Delinquent Accounts.
Such an amount constitutes a debt on the part of the defendant
based on the June 1, 2015 Consolidated Bill hereto attached as
Annex A.

4. Despite demands by plaintiff, defendant failed to respond or pay

the debt as evidenced by the Demand Letters sent by the
undersigned Legal Counsel, dated June 23, 2015, July 15, 2015
and August 3, 2015 Photocopies of which are hereto attached as
Annex B, Annex C, and Annex D and made an integral part
hereof.
PRAYE R
WHEREFORE, it is most respectfully prayed of this Honorable
Court that after due hearing, judgment be rendered in favor of plaintiff
and against the defendant in this manner.
1. Ordering the defendant to pay plaintiff the amount of Nine
Hundred Twenty Six Thousand Two Hundred Sixty Nine & 93/100
Philippine Currency (PHP 926,269.93), with legal rate of interest,
compounded from July 23, 2013, and until the same is fully paid;
2. Issuing a Writ of Preliminary Attachment to Unit H and I on the 5 th
floor of, 2600 Roxas Blvd., corner Pablo Ocampo (formerly Vito
Cruz) Street, Malate, Manila as security for the settlement of this
case; and
3. Ordering the defendant to pay the cost of this suit and attorneys
fees.
Plaintiff likewise prays for such other reliefs as this Honorable
Court may deem just and equitable.
Makati City for Manila City, July 15, 2015.

JERICO D. SALENGA
IBP No. 0987838/1-8-15/Makati City
PTR No. 4754780/1-8-15/Makati City
Roll of Attorney No. 63010
MCLE Compliance No. Exempted
Suite 2311 Cityland 10 Tower II, 154 H.V. Dela Costa St.,
Salcedo Village, Makati City 1227, Philippines
Tel. No: 753-2234
Cell No.: 091 555111 27
Email: jericosalenga@gmail.com

Copy furnished:
SONJA RODRIGUEZ
Defendant
5th floor, Unit H and I,
2600 Roxas Blvd.,
corner Pablo Ocampo Street,
Malate, Manila
EXPLANATION
In compliance with Section 11, Rule 13 of the 1997 Rules of
Civil Procedure, the undersigned counsel states that due to distance,
time and manpower constraints, personal service of this Complaint
was not resorted to and instead, copies of the same were sent by
registered mail pursuant to Section 7, Rule 13 of the said rules as per
attached registry receipt(s).

JERICO D. SALENGA

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
I, Jessie John P. Gimenez, of legal age, President of Legaspi
Towers 300 Inc. located at 2600 Roxas Blvd., corner Pablo Ocampo
(formerly Vito Cruz) Street, Malate, Manila, under oath, do hereby
depose states that:
1. I am the complainant in the said case;
2. I have caused the preparation of the same and I attest to the
veracity of all the allegations stated herein;
3. I have read and understood all the allegations herein and that
I attest to the authenticity and veracity of all the documents
attached herein as based on existing and authentic records;
4. I further certify that I have not commenced or filed any claim
involving the same issues herein with any other Court.
Tribunal or Quasi-Judicial Agency or I am not aware of any
such other case or claim pending before any other court,
tribunal or quasi-judicial agency; and
5. Should I thereafter learn of the filing or pendency of such
similar action or claim, I will inform this Honorable Court of
such fact within five (5) days from knowledge thereof.
IN WITNESS WHEREOF, I have hereunto affixed my hands this
15th day of July, 2015 at Makati City, Philippines.

JESSIE JOHN P. GIMENEZ

Affiant
SUBSCRIBED and SWORN TO before me this 15th day of
July, 2015 at Makati City, Philippines, affiant exhibiting to me her
Drivers License issued on ___th day of _______ 2015 at Makati City,
Philippines.
NOTARY PUBLIC
Doc. No. __________
Page No. __________
Book No. __________

Series of 2015