FORM NO.

13: COMPLAINT WITH PRAYER FOR ATTACHMENT

Republic of the Philippines

Regional Trial Court
National Capital Judicial Region
Branch 1, Manila

Juan Tamad
Plaintiff,
Civil case no. 11111
For: Sum of Money

-versus-

Maria Makiling
Defendant

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

COMPLAINT
(With prayer for attachment)

Plaintiff, by the undersigned counsel respectfully states that:

1. Plaintiff Juan tamad, of legal age, residing at 22 San Miguel

St.Manila; while defendant Maria Makiling is of legal age,
residing at 42 San Antonio St. Manila;
2. Defendand borrowed money from the plaintiff amounting to
P100, 000 and evidenced by a promissory note on December
4,2009, herein attatched as Annex A;
3. The defendant is about to depart the Philippines with intent to
defraud her creditors;
4. There is no sufficient security for the claim sought to be
Recovered from the defendant in the instant action, and the
amount due to plaintiff is as much as the sum for which the
order of attachment may be granted above all legal
counterclaims;
5. Plaintiff is willing to put up a bond for the issuance of the
preliminary attachment in an amount fixed by court, which is
not Exceeding the amount of plaintiff’s claim;

WHEREFORE, it is respectfully prayed that, pending the hearing

of the case, a writ of preliminary attachment be issued against
the property of the defendant to serve as security for the
satisfaction of any judgment that may be recovered herein, and
after due hearing on the principal cause of this action, judgment
be rendered against the defendant for the sum of P100, 000 with
interest at the stipulated rate of twelve per centum per annum
(12%) from January 20, 2010 plus cost of the suit.

City of Manila; March 3 2010.

SIGNATURE OF COUNSEL

Certification of non-forum shopping

Affidavit for Preliminary Attachment
FORM NO. 14: COMPLAINT WITH PRELIMINARY INJUNCTION

Republic of the Philippines

Regional Trial Court National Capital Judicial Region Branch 1,
Manila

Juan Tamad
Plaintiff,

Civil case no. 11111

For: Sum of Money

-versus-

Maria Makiling
Defendant

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

COMPLAINT

Plaintiff, by the undersigned counsel respectfully states that:

1. Plaintiff Juan tamad, of legal age, residing at 22 San Miguel St.

Manila; while defendant Maria Makiling is of legal age, residing
at 42 San Antonio St. Manila;
2. Plaintiff is engaged in the exclusive distribution of Nike products
in the Philippines;
3. Defendant is also engaged in the sale of Nike products in the
Phillipines;
4. As a result of defendants acts, plaintiff suffered damage
amounting to P500,000 a month starting January 20, 2010;
5. Defendant continues to commit the act of illegally interfering with
the agreement between plaintiff and Nike;
6. Plaintiff is entitled to the relief demanded in whole or part, such
relief consists in the discontinuing of the acts complained of for a
limited time or perpetually;
7. Plaintiff hereby applies for a writ of preliminary injunction to
restrain the defendant from the act herein complained of, and for
the purpose offers a bond in such sum this Honorable Court may
fix;
 PRAYER

WHEREFORE it is respectfully prayed that, after due notice and

having a preliminary injunction be issued forthwith to restrain
defendant from doing the act complained of, to cease and desist from
selling products of Nike in the Philippine, and that after trial, said
injunction be made permanent, with costs and such orders which are
deemed equitable.
City of Manila March 3 2010.

SIGNATURE OF COUNSEL

VERIFICATION AND CERTIFICATION OF NON FORUM

SHOPPING
FORM NO.12 : DISCHARGE OF REAL ESTATE MORTGAGE

DISCHARGE OF REAL ESTATE MORTGAGE

KNOW ALL MEN BY THESE PRESENTS:

I, JUAN DELA CRUZ, of legal age, single and with residence and
postal address at No. 17 Acacia Street, Pembo, Makati City, is the
mortgagee in that Deed of Real Estate Mortgage executed by PEDRO
DUHAYLUNGSOD on May 1, 2013 and noted as Doc. No. 2; Page No.
3; Book No. IV; Series of 2013, of the Notarial Register of BEN HUR,
Notary Public for and in the City of Makati;

That having received the full amount of ONE HUNDRED

THOUSAND PESOS (P100,000.00), Philippine Currency together with
accrued interest from the Mortgagor, the said PEDRO
DUHAYLUNGSOD , I do hereby forever RELEASE, DISCHARGE,
and CANCEL the Mortgage mentioned above, covering Lot No. 35 with
Transfer Certificate of Title No. 123456 of the Registry of Deeds of
Makati City.

IN WITNESS WHEREOF, I have hereunto set my hand this 7th

day of February 2018 at Makati City.

JUAN DELA CRUZ

Signed in the presence of:

MARIA MAKILING JUAN TAMAD

ACKNOWLEDGMENT

Republic of the Philippines)

City of Makati ) S.S.
BEFORE ME, a Notary Public, for and in the City of Makati, this 7th day
of January 2014 personally appeared:

Name Identification Card Issued On/At

JUAN DELA CRUZ SSS I.D. No. 169 1-1-11/Makati
MARIA MAKILING SSS I.D. No. 469 4-1-11/Makati
JUAN TAMAD SSS I.D. No. 695 5-1-11/Makati
 all known to me to be the same persons who executed the
foregoing instrument and hereby acknowledged to me that the same is
their free and voluntary act and deed.

WITNESS MY HAND AND NOTARIAL SEAL.

Doc. No. _____

Page No._____
Book No._____
Series of 2018.