Republic of the Philippines

Second Judicial Region

REGIONAL TRIAL COURT
Branch 14

SPOUSES CIVIL CASE NO. ____

and
, For:
Plaintiffs,
COLLECTION OF
SUM OF MONEY
-versus- WITH DAMAGES

SPOUSES
,
Defendants.
X----------------------------------------------------X

COMPLAINT

Plaintiffs, through counsel unto this Honorable Court, respectfully

states that:

1. Plaintiffs are of legal age, Filipinos, married and residents of

______________, , Philippines. They may be served with
court processes through the undersigned counsel;

2. Defendants are likewise of legal age, married, Filipinos and

residents of ______________ Philippines, where they may
be served with summons and other court processes;

3. On February 13, 2018, the Defendants borrowed from the

Plaintiffs a sum of money in the amount of Six Hundred
Thousand Pesos (Php 600, 000.00), Philippine Currency, to be
paid within one (1) year with five (5) percent interest for each
month. As security for the money that the Defendants
borrowed, the Defendants mortgaged two (2) parcels of land
with Tax Declarations registered under the name of
____________ and with both parcels of land located at
_______________. The Mortgage Deed entered into by the
Defendants and Plaintiffs duly acknowledged by a Notary Public
is hereto attached as Annex “A” ;

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 4. The Defendants, after execution of the Mortgage, had been
paying their dues to the Plaintiffs. However, when the month of
August in the year 2018 came, the Defendants did not pay their
dues to the Plaintiffs but the latter were informed that the sari-
sari store of the defendants was burned, thus, the Plaintiffs gave
the Defendants consideration. Thereafter however, the
Defendants did not make good their obligations for the
succeeding months to the Plaintiffs thus, on January 28, 2019,
the latter wrote the Defendants a notice reminding them of
their unpaid dues and that they have to make good of their
obligation. The Letter of Notice sent by the Plaintiffs to the
Defendants on January 28, 2019, duly received by one of the
Defendants, is hereto attached as Annex “B”;

5. After the Notice sent by the Plaintiffs to Defendants, still, the

Defendants did not pay their corresponding dues to the
Plaintiffs thus on February 7, 2019, the Plaintiffs wrote to the
Defendants a letter demanding the latter to pay the principal
amount including the interests thereof. The demand letter sent
by the Plaintiffs to the Defendants on February 7, 2019, duly
received by one of the Defendants on February 9, 2019 is hereto
attached as Annex “C”;

6. Because the Defendants refused to settle their obligation, the

Plaintiffs are constrained and have no other recourse but to hire
a lawyer in the amount of _________________ for this case
to file with this Honorable Court to assert their rights.

PRAYER

WHEREFORE, plaintiff respectfully prays to the Honorable

Court that the judgment be rendered against defendant, as follows:

1. Order the Defendant to pay the Plaintiff the sum of SIX

HUNDRED THOUSAND PESOS (Php 600,000.00), with its
interest stipulated in the mortgage contract;

2. In either case, to order the Defendants to pay the Plaintiffs the

sum of _____________________________ as Attorney’s
Fees, and to pay the costs of the suit; and

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 3. The Plaintiffs also prays for such other and further relief or
reliefs that this Honorable Court may deem it just and
equitable.

_____________________, Philippines, February __, 2019.

______________________
Counsel for the Plaintiff
__________________
PTR # ________________
IBP Lifetime No. ____________
Roll No. ___________
MCLE Compliance No. ________

REPUBLIC OF THE PHILIPPINES

City of Baguio s.s.

VERIFICATION AND CERTIFICATION

AGAINST FORUM SHOPPING

We, ____________________________________,
both of legal age, Filipino, married, after having been duly sworn in
accordance with law, depose and state that:

1. We are the plaintiffs in the above-captioned case which is for

the collection of a sum of money with damages;

2. We have caused the preparation of the foregoing Complaint; We

have read the allegations contained therein and we know the
contents thereof and the allegations contained therein are true
and correct based on our own and personal knowledge and
based on authentic records on hand;

3. We further certify that: (a) we have not theretofore commenced

any other action or proceeding involving the same matter in the
Supreme Court, the Court of Appeals, or any other tribunal or
agency; (b) to the best of our knowledge, no such action or
proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency; and (c) if we should
hereafter learn that a similar action or proceeding has been filed
or is pending therein, we shall undertake to promptly report
such fact within five (5) days there from to this Honorable
Office.

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 IN WITNESS HEREOF, we hereunto set our hands this
___th day of February, 2019 at ____________, Philippines.

________________________________________
Affiant Affiant

SUBSCRIBED AND SWORN to before me this ___th day of

February, 2017 at Baguio City, Philippines, affiant exhibiting to me
her Driver’s License with license number ____________ to expire
on July 16, 2017.

_________________________
Counsel for the Plaintiffs
Poblacion _______________
Doc. No. PTR # _______-___________-1/5/17
Page No. IBP#.________-___________
Book No. Roll No. ___________
Series of 2019 MCLE Compliance No. __________

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