Republic of the Philippines

6TH JUDICIAL REGION

Regional Trial Court
Branch _____
San Pablo City

Maria Makiling, Civil Case No. _____________

Plaintiff FOR: COLLECTION FOR A
SUM OF MONEY WITH
DAMAGES
- Versus -

Juan Cruz,
Defendant
x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court,

hereby respectfully avers:

1. That plaintiff is of legal age, Filipina, and a resident of 186 Garcia

St. City subdivision, San Pablo City, Philippines while the defendant is also
of legal age, married, Filipino and a resident of 185 Garcia St. City
subdivision, San Pablo City, Philippines where summons and court
processes may be served;

2. That on March 30, 2017, the defendant borrowed from the plaintiff
a sum of money amounting to Two Million Pesos (PhP2,000,000.00) with an
agreed interest of five percent (5%) per month as evidenced by a promissory
note herein attached as Annex “A” and form an integral part of this
complaint;

3. That as shown in the attached promissory note, the indebtedness of

the defendant has become due and demandable on March 30, 2018;

4. That despite plaintiff’s repeated written demands, defendant failed,

neglected and refused to fulfill obligations without just and valid grounds to
the continued damage and prejudice of plaintiff, as evidenced by Annex “B”
– Demand Letters;

5. That the plaintiff in order to enforce her rights and interests, has
sought the services of a legal counsel with attorney’s fees amounting to One
Hundred Thousand Pesos (PhP 100,000.00) and an appearance fee of Two
Thousand Pesos (PhP 2,000.00) per hearing as evidenced by Annex “C” –
Contract for Legal Services;
6. That the plaintiff has paid for litigation expenses amounting to
Twenty Thousand Pesos (PhP 20,000.00) as evidenced by Annex “D” –
Official Receipt;

7. That the plaintiff has suffered moral damages at the sum discretion
of the Honorable Court;

WHEREFORE, premises considered, it is hereby respectfully prayed

before the Honorable Court to render decision in favor of the plaintiff and
order the defendant to pay the following:

a. the sum of Two Million Pesos (PhP 2,000,000.00) plus interest at

the rate of five percent (5%) per month as stipulated in the
promissory note;

b. moral damages, exemplary damages at the sum discretion of the

court;

c. attorney’s fees amounting to One Hundred Thousand Pesos (PhP

100,000.00) and an appearance fee of Two Thousand Pesos (PhP
2,000.00) per hearing

d. litigation expenses amounting to Twenty Thousand Pesos (PhP

20,000.00).

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

San Pablo City, April 6, 2018.

ATTY. KEVIN Q. AMANTE

Counsel for Petitioner
Amantee Law Office, Maharlika St., San Pablo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, San Pablo City
IBP NO. 123456, 01/04/14, San Pablo City
MCLE Comp. No. IV-0009876, 01/02/18
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF LAGUNA ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, Maria M. Makiling, of legal age, Filipina, and a resident of 186

Garcia St. City Subdivision, San Pablo City, Philippines, after being sworn
in accordance with law, hereby depose and say:

(1) That I am the Plaintiff in the above-entitled case;

(2) That I have caused the preparation of the above Complaint and I
have read the same and understood the contents thereof;

(3) That the allegations contained therein are true and correct of my
own personal knowledge and based on authentic records.

(4) That I further certify that: I have not theretofore commenced any
other action or proceeding or filed any claim involving the same issues or
matter in any court, tribunal, or quasi-judicial agency and, to the best of my
knowledge, no such action or proceeding is pending therein; if I should
thereafter learn that the same or similar action or proceeding has been filed or
is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5)
days therefrom to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 6th day

of April 2018 at San Pablo City, Philippines.

Maria M. Makiling
Affiant
TIN 98765-111; San Pablo City
 SUBSCRIBED AND SWORN to before me, this 6th day of April
2018, affiant exhibiting to me her Tax Identification Card as shown above
below here name as competent evidence of his identity.

ATTY. KEVIN Q. AMANTE

My Commission No. is 58
Expires on December 31, 2018
Amante Law Office, Maharlika St., San Pablo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, San Pablo City
IBP NO. 123456, 01/04/14, San Pablo City
MCLE Comp. No. IV-0009876, 01/02/18

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2018;