REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

City of Mandaluyong
Branch 1
PAUTANG INCORPORATED
represented by Asiong Aksaya,
President,
Plaintiff,
CIVIL CASE No. 0001
FOR: Collection of sum
of money

-versusGARY GASTOS,
Defendant.
x-----------------------------------x
COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and

unto this Honorable Court, most respectfully avers:
1.
That the plaintiff, is a finance and lending corporation duly organized
and existing under the Laws of the Philippines, having its principal office at
68 Shaw Blvd, Mandaluyong City;
2.
That the defendant, GARY GASTOS, is of legal age, Filipino citizen,
single, with residence and postal address at 69 Shaw Blvd, Mandaluyong
City, where they may be served with summons and other court processes;
3.
By virtue of a contract of loan executed June 1, 2013 hereto attached
as Annex "A", the defendant obtained a loan from the plaintiff in the sum of
Eight Hundred Thousand Pesos (P800,000.00) Philippine Currency, with the
following terms and conditions among others:
a. The principal loan obligation shall be payable in 1 year from
the execution of the agreement;
b. The principal shall be paid on installment basis on which there
will be 4 payments of One Hundred Twenty Five Thousand
Pesos (P125,000) and last payment of Four Hundred Twenty
Five Thousand Pesos (P425,000);
c. The 1st payment of the installment amount shall be paid on the
month of September 2013, 2nd payment on December 2013,
3rd payment on March 2014 and the last payment on June
2014;
d. The principal loan obligation shall incur an interest of 10% per
month compounded in the event of delay in payment.
4.

The defendant failed to pay the last installment amount of FOUR

HUNDRED TWENTY FIVE THOUSAND PESOS (P425,000) for the last
payment month of June 2015;

5.

On July 1, 2014, defendant executed a promissory note in favor of the

plaintiff in the amount of P 425,000 payable within 30 days from the date of
the promissory note hereto attached as Annex "B" which reads as follows:
Mandaluyong, Philippines
1 July 2014

I promise to pay PAUTANG INC. the sum of P125,000 or order

within 30 days from this date.
GARY GASTOS

6.

That the 30-day period had elapsed and despite demands made orally
and in writing (attached as Annex C) by the plaintiff, defendant refused
and failed to pay the amount stated in the promissory note.
7.
That due to the unjust refusal of defendant to comply with the
demands, plaintiff was compelled to file the instant action engaging the
services of counsel in the amount of P50,000.
WHEREFORE, premises considered, it is most respectfully prayed
unto this Honorable Court that, after hearing, judgment be rendered ordering
the defendant:
1.
2.

To pay the amount of P425,000 due last June 30, 2014 with interest;
To pay the plaintiff the cost of the suit.
City of Mandaluyong, January 1, 2015.
ABAD AND AGRA LAW OFFICE
Counsel for the Plaintiff
Antipolo City
By:
La Verne A. Abad
Roll of Attorney No. 00001
IBP No. 12345/2-5-12/Antipolo
PTR No. 87654/12-22-11/Antipolo
MCLE Compliance Certificate No. 00001/ 1/1/2015/Antipolo
By:
Jeare Agra
Roll of Attorney No. 00002
IBP No. 12345/2-6-12/Antipolo
PTR No. 87654/12-23-11/Antipolo
MCLE Compliance Certificate No. 00002/ 1/2/2015/Antipolo
VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Mandaluyong
) S.S.

1.
2.
3.
4.

5.

6.

I, Asiong Aksaya, President of PAUTANG INC, located at at 68 Shaw

Blvd, Mandaluyong City, under oath, do hereby depose and state that:
That I am the plaintiff in the above-entitled case;
That I have caused the preparation of the foregoing complaint and
have read the allegations contained therein;
The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
I hereby certify that I have not commenced any other action or
proceeding involving the same issues in any court, tribunal or quasi-judicial
agency and, to the best of my knowledge, no such other action or claim is
pending therein;
That if I should learn thereafter that a similar action or proceeding has
been filed or is pending, I hereby undertake to report that fact within five (5)
days therefrom to the court or agency where the original pleading and sworn
certification contemplated herein have been filed;
I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular No. 0494 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
1st of January 2015, in the City of Mandaluyong.
Asiong Aksaya
Affiant
SUBSCRIBED AND SWORN to before me this 1st day of January,
2015, in the City of Mandaluyong, affiant exhibiting to me:
ID
1. Drivers License
2. SSS

No.
12345
12345

Issued on/Issued at
June 1 2013/Mandaluyong City
June 1 2002/Mandaluyong City
ATTY. HIMALA
Notary Public
My Commission Expires Dec. 31, 2015
Roll of Attorney No. 45456
IBP No. 12345/2-5-12/Mandaluyong
PTR No. 87654/12-22-11/Mandaluyong

Doc. No. __1____

Page No. __1____
Book No. __1____
Series of 2015.