COMPLAINT

PLAINTIFF, through counsel, most respectfully avers:

(1.) That plaintiff, Alexander Sison is a Filipino citizen, of

legal age, single and a resident of 111 Libertad St.
Sampaloc Manila, whereas, defendant Juan Jamero is
likewise a Filipino, of legal age, single, and residing at
222 Juan Luna St., Tondo Manila, at which address the
party herein may be served with summons and other
court processes;

(2.) That on January 3, 2008, defendant borrowed from

plaintiff the amount of one million pesos (Php.
1,000,000.00) , which indebtedness is due and payable
on or before January 3, 2009, with an interest at the
rate of 12% per annum within one (1) year, in
accordance with the promissory note executed by the
defendant on the said date. Photostatic copy of said
promissory note is attached and marked as Annex “A”
and made as a integral part hereof;

(3.) That the defendant has failed and refused and still fails
and refuses to pay the said indebtedness on due date,
with corresponding interest thereon to the herein
plaintiff, despite repeated requests and demands.

(4.) That the plaintiff served several demands to the

defendant, attached is the last demand letter executed
on July 01, 2009 by the plaintiff as annex “B” and
made as an integral part hereof;

(5.) That the defendant shall pay for the attorney’s fees and
expenses of litigation in the amount of Php. 75,000.00
and a fee of P3,000 for every appearance in court, and
to pay the cost of this suit;

(6.) That the plaintiff is willing to put up a bond for the

issuance of a preliminary attachment in an amount to
be fixed by the court, not exceeding the sum of one
million pesos which is the plaintiff’s claim herein;

Allegations for the Issuance of for Preliminary Attachment

 Plaintiff further states and alleges:

(7.) That Plaintiff has a valid and sufficient cause of action

against the herein defendant regarding the collection of
sum of money which is already due and demandable;

(8.) Defendant has removed or disposed of or is about to

remove or dispose of her property, with intent to
defraud her creditors thereby rendering nugatory and
ineffective whatever money judgment this honorable
court may render in the above entitled case;
(9.) That the defendant does not have sufficient security for
the claim sought for the plaintiff against him;

(10.) That the plaintiff is willing to put up a bond for the

issuance of a preliminary attachment in an amount to
be fixed by the court, not exceeding the sum of one
million pesos which is the plaintiff’s claim herein;

PRAYER

WHEREFORE, it is most respectfully prayed of this

Honorable Court that pending hearing of this 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 that after due hearing on the principal cause
of this action, judgment be rendered against the
defendant for the sum of the following:

(1.) Ordering defendant to pay plaintiff the amount of one

million pesos (Php. 1,000,000.00) plus interest thereon
at the rate of 12% per annum from January 3, 2009,
and until the same is fully paid; and

(2.) Ordering defendant to pay the attorney’s fees and

expenses of litigation in the amount of Php. 75,000.00
and a fee of P3,000 for every appearance in court, and
to pay the cost of this suit;
Plaintiff likewise prays for such other and further
relief or reliefs as this Honorable Court may deem just
and equitable under the premises.
Manila, Philippines, September 01, 2009.

MARY JOY S. DEJADA

Counsel for the Plaintiff
4321 suite, Makati Manila