REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH _____, MANILA

MARIEL A. DE LEON,
Plaintiff,

- versus - CIVIL CASE NO. 17-______

FOR: COLLECTION OF SUM OF
MOCHA A. USON, MONEY
Defendant.

x------------------------------------x

COMPLAINT

Plaintiff, by counsel, respectfully states that:

1. That plaintiff is a Filipino, of legal age, single and residing at 123 Taft
Avenue, Malate, Manila, where she may be served with summons papers
and other process of this Honorable Court;

2. That defendant, MOCHA A. USON, is a Filipino of legal age, single and

residing at 987 U.N. Avenue, Malate, Manila, where he may be served with
summons, papers and other process of this Honorable Court;

3. That on January 1, 2017, defendant came to plaintiff’s house to asked for

a loan in the amount of eight hundred thousand pesos (P800,000.00)
Philippine currency to which the plaintiff granted;

4. That defendant executed a Promissory Note promising to pay the principal

amount with 3% interest on June 2, 2017. A copy of which is hereto attached
as “Annex A”;

5. That plaintiff made the repeated demand from defendant but defendant
failed to pay;

6. That plaintiff wrote a final demand letter to defendant on August 2, 2017

which was received by the defendant on the same day. Attached herein as
“Annex B”;

7. That up to this date defendant failed to make good of his promise to pay the
plaintiff of the principal amount plus interest.

PRAYER

WHEREFORE, it is respectfully prayed that after due hearing, judgment be

rendered ordering the defendant:

1. To pay P800, 000 by virtue of defendant’s promissory note plus interest;

2. To pay attorney’s fees and costs of the litigation;

3. Such other relief as may be just and equitable under the premises are likewise
prayed for.

City of Manila, Philippines, August 25, 2017.

1
 ANDY A. BAUTISTA
Counsel for the Plaintiff
224-B Macho Street, Sta. Mesa Heights
Quezon City, Metro Manila
IBP OR NO. 01010-8/1/95-Romblon
(Lifetime Member)
PTR NO. 1234567C-02/03/17-Q.C. MM
Attorney’s Roll No. 32827
MCLE Compliance No. V-123456/26 June 2017
Tel. Nos. 123-4567 & 765-4321

VERIFICATION AND CERTIFICATION AGAINST FORUM-SHOPPING

REPUBLIC OF THE PHILIPPINES)

QUEZON CITY, METRO MANILA) S.S.

I, MARIEL A. DE LEON, Filipino, of legal age, single and residing at 123

Taft Avenue, Malate, Manila, after having been duly sworn to in accordance with
law depose and say:

That I am the Plaintiff in the above-entitled case;

That I have caused the preparation of the above Complaint and I have read
the same and knows the contents thereof;

That the allegations contained therein are true and correct of my own
personal knowledge.

That I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;

That to the best of my knowledge and belief, no such action or proceeding

is pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;

That if I should thereafter learn that a similar action or proceeding has been
filed or is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days therefrom to
this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 10th day of

August, 2017 at Manila City, Philippines.

____MARIEL A. DE LEON______
Affiant

SUBSCRIBED and sworn to before me, this 20th day of August, in the City
of Manila by Ms. De Leon with Passport No.1234567 issued by DFA-Manila on
31 May 2016 to expire on 30 May 2020.

Doc. No.__________
Page No.__________
Book No.__________
Series of 2017

2
3