COMPLAINT

COMES NOW Plaintiff, by counsel and to this Honorable Court, respectfully states that:

1. Plaintiff _____________ is of legal age, Filipino, (single / married / widow), and a resident

of _____________, Philippines. For purposes of this action, plaintiff may be served with

all orders, notices, and other processes of this Honorable Court through the office address

of the undersigned counsel indicated below;

2. Defendant _____________, of legal age, Filipino, (single / married / widow), and may be

served with summons and other processes of this Honorable Court at his last known address

at _____________, Philippines;

3. Sometime on _____________, Defendant obtained from and was granted a loan

accommodation by the Plaintiff in the principal amount of __________________________

(P_____________), Philippine Currency;

4. A true and faithful machine reproduction of the Promissory Note made by the Defendant

on _____________ is hereto attached as Annex "A";

5. As of _____________, Defendant still has an Outstanding Balance to Plaintiff amounting

to __________________________ (P_____________), Philippine Currency, and has

failed and neglected to pay, without just and valid grounds, the said Outstanding Balance

for the aforementioned loan accommodation;

6. Despite Plaintiff's repeated demands, both written and verbal, Defendant failed, neglected

and refused, and continues to fail and refuse to pay and to settle the said Outstanding

Balance, without just and valid grounds, to the continued damage and prejudice of Plaintiff;

7. A true and faithful machine reproduction of the Plaintiff's demand letter to Defendant dated

_____________ is hereto attached as Annex "B";

8. Consequently, Plaintiff was constrained to engage the services of counsel to whom it

obligated itself to pay as Attorney's Fees the amount equivalent to _____________

(______%) percent of the total amount due from Defendant to Plaintiff.

PRAYER

WHEREFORE, after due notice and hearing, Plaintiff respectfully prays that judgment be

rendered against the Defendant as follows:

1. Ordering the Defendant to pay Plaintiff the sums of:

 a. The amount of __________________________ (P_____________),

representing Defendant's Outstanding Balance plus interest at the rate of

_____________ (_____%) per month as stipulated upon in the Promissory

Note;

b. _____________ (_____%) percent of the total amount due as Attorney's Fees

plus Appearance Fee at the rate of P__________ per court hearing /

conference;

c. _____________ (_____%) percent of the total amount due as Collection

Charges / Liquidated Damages;

d. The costs of suit.

2. Plaintiff respectfully prays for such other reliefs as may be just and equitable in the

premises.

Date _____________, Philippines, __Date__.

(COUNSEL)
 VERIFICATION

REPUBLIC OF THE PHILIPPINES)

Province of ____________________) S.S.
City/Municipality of _____________)
x-----------------------x

I, _____________, of legal age, Filipino, (single / married / widow), and a resident of

_____________, Philippines, after being sworn in accordance with law, hereby depose and say:

That I am the (Plaintiff / Complainant / Petitioner) in the above-entitled case; That I have
caused the preparation of the above (Complaint / Petition) 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.

IN WITNESS WHEREOF, I have hereunto set my hand this _____________ at

_____________, Philippines.

AFFIANT

SUBSCRIBED AND SWORN to before me, this _____________, by _____________

who exhibited to me (his/her) Community Tax Certificate No. _____________ issued at
_____________, Philippines on _____________.

NOTARY PUBLIC

Doc. No. ______;

Page No. ______;
Book No. ______;
Series of ______;
 CERTIFICATION OF NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES)

Province of ____________________) S.S.
City/Municipality of _____________)
x-----------------------x

I, _____________, of legal age, Filipino, (single / married / widow), and a resident

of _____________, Philippines, after being sworn in accordance with law, hereby depose
and say:

That I am the (Plaintiff / Complainant / Petitioner) in the above-entitled case and I

certify that: (a) 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; (c) 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 _____________ at

_____________, Philippines.

AFFIANT

SUBSCRIBED AND SWORN to before me, this _____________, by

_____________ who exhibited to me (his/her) Community Tax Certificate No.
_____________ issued at _____________, Philippines on _____________.

NOTARY PUBLIC

Doc. No. ______;

Page No. ______;
Book No. ______;
Series of ______;