13 March 2020

TO: MR. PEDRO SANTOS

#123 Alalum, Municipality of San Pascual

Batangas

Mr. Santos:

I am writing to you on behalf of my client, JUAN DE LA CRUZ, owner of JUAN

POULTRY SUPPLY, with office address at C. Tirona St., Batangas City. It appears on
record that you have an outstanding obligation amounting to Php 530,000.00 worth of
poultry feeds and supplies, as evidenced by the following:

Date                        Sales Invoice No.                          Amount

 Oct.  2, 2019                   12301                                 P 50,000.00

 Nov. 6, 2019                   12311                                   100,000.00

 Dec. 5, 2019                   12315                                   100,000.00

 Jan. 5, 2020                   12325                                    150,000.00

 Feb. 9, 2020                   12335                                      50,000.00

 Mar. 3, 2020                   12350                                      80,000.00

                            Total (inclusive of interest)        P 530,000.00

Records show that you have not made any payment for the mentioned purchases. You are
therefore demanded to settle your obligation for a non-extendible period of ten (10) days
from receipt of this letter. Failure to settle the amount will result in a corresponding legal
action.

Sgd.

ATTY. DIANA MAE C. CALANGI

Office address: 218 Sesame St., Arce Subdivision,

Hilltop, Kumintang Ibaba, Batangas City

 REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF BATANGAS

JUDICIAL DISTRICT

BRANCH 4

A,

JUAN DE LA CRUZ

Plaintiff,

- versus - Civil Case No. 12345

For: Sum of Money

B,

PEDRO SANTOS

Defendant,

x ------------------------------------- x

COMPLAINT

PLAINTIFF, through counsel, most respectfully states:

1. That plaintiff is a Filipino, of legal age, married, and residing at C. Tirona St.,
Batangas City, whereas defendant is likewise a Filipino, of legal age, single, and
residing at #123 Alalum, San Pascual, Batangas, at which addresses the parties
herein may be served with summons and other court processes;

2. That plaintiff is a sole proprietor engaged in the sale of poultry feeds and supplies,
doing business under the name Juan Poultry Supply, with business address at C,
Tirona St., Batangas City. It sells poultry feeds and supplies on cash and on credit
subject to a 5% interest to certain trusted clients;

3. On six (6) separate occasions, the defendant bought on credit plaintiff’s goods
under the condition that they be paid within ten (10) days from the of invoice plus
five percent (5%) interest. The transactions are specifically stated as follows:

Date                        Sales Invoice No.                          Amount

Oct.  2, 2019                   12301                                 P 50,000.00

Nov. 6, 2019                   12311                                   100,000.00

Dec. 5, 2019                   12315                                   100,000.00

 Jan. 5, 2020                   12325                                    150,000.00

Feb. 9, 2020                   12335                                      50,000.00

Mar. 3, 2020                   12350                                      80,000.00

4. On March 13, 2020, plaintiff discovered that the defendant did not make good
their arrangement as to the payment of the said transactions, despite the same
having already been due and demandable. This prompted the plaintiff to acquire
the services of a lawyer and send a demand letter to the defendant on the same
date requiring the latter to pay the total amount of FIVE HUNDRED THIRTY –
THOUSAND PESOS (Php530,000.00). A copy of the demand letter is attached
to this complaint as Annex “A”;

5. That the defendant has failed and refused and still fails and refuses to pay the said
indebtedness on due date, with the corresponding interest thereon to the herein
plaintiff, despite repeated demands, both oral and written.

6. Attached hereto is a copy of the demand letter addressed to the defendant dated
March 13, 2020, with his signature.

WHEREFORE, it is most respectfully prayed of this Honorable Court that after due
hearing, judgment be rendered in favor of plaintiff and against the defendant in this
manner:

1. Ordering the defendant to pay plaintiff the amount of FIVE HUNDRED

THIRTY – THOUSAND PESOS (Php530,000.00), inclusive of 5%
interest;

2. Ordering the defendant to pay the costs of this suit.

Plaintiff likewise prays for such other and further relief or reliefs as this Honorable
Court may deem just and equitable in the premises.

JUAN DE LA CRUZ

Affiant / May 8, 2020

Batangas City
SUBSCRIBED AND SWORN to me before this 8th day of May 2020, affiant exhibiting
his Postal ID with PRN F12300056920 P, issued by PhilPost at Batangas City, valid until
January 31, 2021.

ATTY. DIANA MAE C. CALANGI

NOTARY PUBLIC
Notarial Comm. Serial No. 2019-20-R
Until December 31, 2020
PTR No. 135792 /01-02-20/ Batangas City
IBP LR No. 03040/ March 4, 2019/ Batangas City
Roll of Attorney’s No. 76849
MCLE Compliance No. VI-0312884;
Dated 05-30-2022
218 Sesame, Arce Subdivision, Batangas City
 VERIFICATION OF NON-FORUM SHOPPING

I, JUAN DE LA CRUZ, Filipino, of legal age, married and residing at C. Tirona

St., Batangas City, under oath, depose and state:

1. That I am the plaintiff in the above-entitled case;

2. That I have caused the preparation and filing of the said complaint for Collection
of Sum of Money;

3. That I have read and understood the contents and the same are true and correct of
my own knowledge and based on authentic records;

4. That I have not commenced or filed any action involving the same issues in any
court, tribunal or agency; that of my own knowledge, no such action is pending in
court, tribunal or agency; that should I hereafter learn of any such pending action,
I undertake to inform this Honorable Office of such fact within five (5) days
therefrom.

IN WITNESS WHEREOF, I have hereunto set my hand this 8th day of May 2020, in
Batangas City.

JUAN DE LA CRUZ

Affiant / May 8, 2020

Postal ID PRN F12300056920 P

Batangas City
 CERTIFICATION

I hereby certify that I have read the pleading and that to the best of my
knowledge, information and belief, there is good ground to support it and it is not
interposed for delay.

I also hereby certify that the document is not being presented for any improper
purpose; that the claims, defenses, and other legal contentions are warranted by existing
law or jurisprudence or by non-frivolous argument for modifying or reversing existing
jurisprudence; that the factual contentions have evidentiary support or will have
evidentiary support after availment of the modes of discovery; and that the denials of
factual contentions are warranted by evidence, or reasonably based on belief or lack of
information.

Signed:

ATTY. DIANA MAE C. CALANGI

Counsel for the Plaintiff