Beruflich Dokumente
Kultur Dokumente
BLACK TOPS
Owned by RICA OCAMPO,
Defendant.
x-----------------------------------------x
C O M PLAI N T
PLAINTIFF, Thru counsel, respectfully avers that:
THE PARTIES
Plaintiff MARCO POLO, is a Filipino citizen, of legal age, single,
with residence and postal address at #39 Block-2 Lot-11 Maharlika
Village, Taguig City. He may be served with summonses and other
processes of this Honorable Court through the undersigned Counsel.
Defendant RICA OCAMPO, likewise Filipino, of legal age, with
residence address at 123 Dimahanap Street, Pasay City, where they
may be served with summonses and other processes of this Honorable
Court.
FACTUAL ANTECEDENT ALLEGATIONS
COMMON TO ALLCAUSES OF ACTION
1. Plaintiff is an independent proprietor, doing business under the
law of the Philippines engaged in construction of buildings
under the name of ABC Construction Company, with the
business address at 123 Global, Taguig City;
10. That the defendant withheld payment of the final billing in the
amount of P600,000.00, including the disputed cost of
replacement materials. The plaintiff thus sent several demand
letters but defendant still failed to pay, unless plaintiff adjusts
the amount she is disputing which amounts to P300,000.00
including man hours for the laborers.
P R AYE R
WHEREFORE, premises considered, it is respectfully prayed
of this Honorable court: that after due hearing judgment be rendered:
1. Ordering Defendant to comply with the written contract
entered into between both parties and to pay the unpaid
balance amounting to P600,000.00;
2. Ordering the Defendant to pay the Plaintiff the amount of
P100,000.00 as Moral damages;
3. Ordering the Defendant to pay the Plaintiff the amount of
P100,000.00 as Exemplary damages;
4. Ordering the Defendant to pay the Plaintiff the amount of
P100,000.00 as attorney fees;
5. And finally, ordering the Defendants to pay the cost of
the suit.
Other reliefs just and equitable in the premises are likewise
prayed for.
Taguig City, this 1st day of January 2016.
ATTY. DATUMAMA P. FERNANDEZ, JR.
Notary Public for the City of Taguig
Commission Series No. 12345
Until December 31, 2017
Office address
Roll of Attorney No. 12345
IBP No. 12345 /Jan. 1, 2014/Taguig
PTR No. 12345/Date/Place of issue
MARCO POLO
affiant
JURAT
SUBSCRIBED and sworn to before to before me this 1 th day of
January 2016, in the City of Taguig, by MARCO POLO who is
personally known to me/exhibited to me his Drivers License No.
12345 issued on January 12, 2014 at Taguig City.
WITNESS MY HAND AND SEAL on the date and place first
above-written.
ATTY. DATUMAMA P.
FERNANDEZ, JR.
Doc No. ______
Page No.______
Book No. ______
Series of 2014
City
PTR No. 12345/Jan. 1, 2015/Taguig
City