Question

(a) Seven years ago today, the Paramount Bank, doing business in 777 Ayala Avenue, Makati City,
granted Juan Reyes, a resident of 888 Kamias, Quezon City, a P1,000,000.00 loan, with 14%
interest per annum, secured by a real estate mortgage over a property located in Cavite City.
The full amount, plus the interest due, was payable on the fifth anniversary of the loan. The
above stipulations were contained in a well-documented and duly executed agreement. Despite
demand, Juan Reyes refused to settle the loan obligation. The bank opted for the filing of a
simple complaint for a sum of money.

Answer

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
MAKATI CITY
PARAMOUNT BANK,
Plaintiff,
-versus- Civil case No.______________
JUAN REYES,
Defendant.
x----------------------------------------x
COMPLAINT
Plaintiff, by undersigned counsel, to this Honorable Court respectfully alleges that:
1. Plaintiff is a banking corporation organized and existing under the laws of the Philippines,
with principal office at 777 Ayala Avenue, Makati City, while defendant is of legal age, and a
resident of 888 Kamias St., Quezon City, where he may be served with summons;
2. On September 28, 1996, defendant borrowed from the plaintiff the amount of
P1,000,000.00, subject to interest at the rate of 14% per annum, payable on the fifth
anniversary of the loan and secured by a real estate mortgage over a parcel of land located
in Cavite City, as evidenced by an agreement executed on the same date, a copy of which is
hereto attached as Annex “a” hereof;
3. Defendant failed to pay the said loan and interests thereon on the due date thereof, ad
continues to fail to pay the same until the present, despite demands of the plaintiff;
4. Due to defendant’s unjustified failure to comply with plaintiff’s plainly just and valid claim,
plaintiff was compelled to initiate this action and retain the services of the undersigned
counsel and to incur expenses in the amount of P100,000.00 as and by way of attorney’s
fees.

WHEREFORE, it is respectfully prayed that, after due hearing, judgement be rendered ordering
the defendant to pay the plaintiff the amount of P1,000,000.00 with interest thereon at the rate of 14%
per annum from September 28, 1996 until fully paid, plus the amount of P100,000.00 for and as
attorney’s fees.

Plaintiff prays for such other and further reliefs as may be just or equitable under the premises.

Makati City, September 28, 2003.

 (Sgd)
Counsel for the Plaintiff
(address)
PTR OR No._____, Makati City, January 3, 2003
IBP OR No. _____, Makati City, January 20, 2003
Attorney’s Roll No._____, (date)

CERTIFICATION AGAINST FORUM SHOPPING

I, A.B., do hereby certify that I am the President of the Paramount Bank, plaintiff in the above-
entitled case; that I have been duly authorized by the Board of Directors of the said bank to execute this
Certification against Forum Shopping, as evidenced by the Secretary’s Certificate of Board Resolution
hereto attached as Annex “B” hereof; that the Plaintiff has not filed any other case in any other court or
administrative tribunal involving the same cause of action; that I am not aware of any pending case
involving the same cause; and should I hereafter acquire knowledge of such other action, I will notify
this Honorable Court thereof within five (5) days from acquiring such knowledge.
Makati City, September 28, 2003.
A.B.
th
SUBSCRIBED AND SWORN to before me this 28 day of September, 2003 the affiant exhibiting to
me his Community Tax Certificate No. ___________ issued at Makati City, On January 31, 2003.

NOTARY PUBLIC
DOC NO.
PAGE NO.
BOOK NO.
SERIES OF 2003

(b) Six-year old Maria informed her mother Divina that on 02 June 2003, her father entered her
bedroom and inserted is middle finger into her vagina. Maria later underwent a medical
examination. The medical findings revealed that she had fresh slight lacerations.

You are the prosecutor, prepare the appropriate information for the crime committed.

Prepare the complaint, indicating the court which has proper jurisdiction and venue.

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL REGION
REGIONAL TRIAL COURT
MANILA
PEOPLE OF THE PHILIPPINES,
Plaintiff,
-versus- CRIM. CASE No.___________
________________________ For: Rape
Accused.
x------------------------------------------x
 INFORMATION
The undersigned City Prosecutor hereby accuses ________________ for the crime of Rape
committed as follows:
That on or about June 2, 2003, at about _____p.m., in _____________________ and within the
jurisdiction of this Honorable Court, the said accused did then and there willfully, unlawfully and
feloniously, through force and intimidation, inserted the middle finger of his right hand in the genital
organ of Divina ______________, who is his own daughter and is only six (6) years of age.
CONTRARY TO LAW.
Manila, September 28, 2003.

CITY PROSECUTOR
City of Manila
CERTIFICATION
I hereby certify that a preliminary investigation was conducted in the above-entitled case, and
there is a prima facie evidence that the crime of Qualified Rape has been committed and that the
accused is probably guilty thereof.