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REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION


REGIONAL TRIAL COURT
Branch 1, Angeles City

BING GO CIVIL CASE NO: 2345678


Plaintiff, FOR: SUM OF MONEY

- versus -

KOKO KRUNTS
Defendant.

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COMPLAINT

Plaintiff, through the undersigned counsel and unto this Honorable


Court respectfully alleges that:

1. The plaintiff is of legal age, single, Filipino citizen and a resident of


123 Salingpusa Street, Barangay Balibago, Angeles City, where he may
be served notices and other court processes;

2. The defendant is also of legal age, single, Filipino Citizen and a


resident of 456 Magulang Street, Barangay Balibago, Angeles City;

3. Sometime in January 2020, the defendant borrowed One Million Pesos


(₱1,000,000.00) from the plaintiff. The defendant promised to pay the
full amount on March 1, 2020. Attached herein is the Promissory Note
as ANNEX “A”;

4. Despite several oral and written demands by the plaintiff, the defendant
failed to pay. These demand letters are attached herein as ANNEX “B”
and “C”;

5. The plaintiff was constrained to file an action with the Lupong


Tagapamayapa of Barangay Salapungan, Angeles City on March 5,
2020;

6. As stated in the Certification to File Action (ANNEX “D”) issued by


the said Lupon on March 10, 2020, conciliation was set on March 9,
2020. However, it was only the plaintiff who appeared in the
conference, thus, no settlement was reached;

7. Defendant’s obligation is due and demandable and plaintiff is entitled


to the payment of the entire amount of One Million Pesos
(₱1,000,000.00) plus legal interest;

8. Due to the defendant’s malicious and wanton refusal to pay the


obligation and failure to appear in the conciliation proceedings before

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the Barangay’s Lupon, plaintiff was constrained to hire the services of a
lawyer to protect his rights and interests for a fee of Fifty Thousand
Pesos (₱50,000.00) for which defendant should be made answerable to
plaintiff;

PRAYER

WHEREFORE, WITH ALL THE FOREGOING, it is respectfully


prayed unto this Honorable Court that judgment be rendered in favor of the
plaintiff and to:

1. Order the defendant to pay the plaintiff the amount of ONE


MILLION PESOS (₱1,000,000.00), with legal interest, as
ACTUAL DAMAGES; and

2. Order the defendant to pay plaintiff the amount of FIFTY


THOUSAND PSESOS (₱50,000.00) as attorney's fees.

Other reliefs just and equitable under the circumstances are likewise
prayed for.

IN WITNESS WHEREOF, I have hereunto affixed my signature this


3rd day of April 2020, at Angeles City, Pampanga, Philippines.

Iris Galecio
IRIS GALECIO
Counsel for the Plaintiff
Roll of Attorney No: 88888
PTR No: 12345678 / 1-8-2020
IBP No: 876543 / 1-8-2020
MCLE Comp. No.: III-0011223

209 AUF PS Building, Salapungan


Angeles City

VERIFICATION AND CERTIFICATION

I, BING GO, of Legal age, single, Filipino Citizen and a resident of


123 Salingpusa Street, Balibago, Angeles City, after being sworn according
to law, hereby depose and state that;

1. I am the plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are
true and correct of my personal knowledge and/or on the basis of
copies of documents and records in my possession;

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4. I have not commenced any other action or proceeding involving
the same issues in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or


proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding has


been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report
that fact within five (5) days therefrom to this Honorable Court.

BingGo
BING GO
Affiant

SUBSCRIBED AND SWORN to before me this 3rd day of April


2020 at Angeles City, Pampanga, Philippines, affiant exhibiting to me his
Driver’s License No. 12345 issued by the Land Transportation Office in
Angeles City on October 20, 2019.

SM
SAMANTHA MORALES
Notary Public of Angeles City
Until December 31, 2020
Roll of Attorney No: 88888
PTR No: 12345678 / 1-8-2020
IBP No: 876543 / 1-8-2020
MCLE Compliance No.: III-0011223

Doc. No. 19;


Page No. 2;
Book No. 1;
Series of 2020.

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