REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH XXX, MANILA

MARIA REYES
Plaintiff

-versus- Civil Case No. 000

For: Collection of Sum of Money with Damages

JOSE SANTOS
Defendant

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

COMPLAINT

Plaintiff thru counsel, and unto this Honorable Court, respectfully manifest:

1.That plaintiff Maria Reyes is of legal age, married and resident of Araneta
Avenue, Quezon City;

2. That defendant is also of legal age, single and resident of Tondo, Manila;

3.That for the cause of action against defendant, it is stated that on January
01,2019, plaintiff (Lender/Creditor) entered into a loan agreement with the defendant
(Borrower/Debtor) with the following conditions:

a. Loan amount- Php 1 Million

b. Payable in between (12 months)
c. Interest: 1% a month

4. That the loan was secured by a Real Estate Mortgage. Real Property subject
of mortgage is a parcel of land covered by Transfer Certificate of Title (TCT) No.
YYYYYY, located in Sta. Ana Manila, owned by the Defendant.

5. That the defendant paid amortizations for the first three (3) months but failed to
pay for the remaining nine (9) months. Unpaid loan amount total is Php 800,000.
 6. That the plaintiff made several verbal demands to defendant. Defendant
promised to pay the unpaid loan amount, but, until present, the loan has not yet been
paid.

7. That a formal written demand to pay, prepared and signed by the Plaintiff’s
counsel, was sent to the Defendant on March 31, 2020 still the defendant did not reply.

WHEREFORE, IN VIEW OF THE FOREGOING, plaintiff through counsel pray

this Honorable Court, after due hearing, to adjudge defendant Jose Santos, to pay the
following:

a. Unpaid loan amounting to Php 800,000.00

b. Attorney’s fees amounting to Php 50,000.00
c. Moral Damages amounting to Php 200,000.00

or total of damages for plaintiff in the sum of ONE MILLION FIFTY THOUSAND PESOS
(Php 1,050,000.00), with legal interest from the date of filing this suit, plus costs of suit,
and such other remedies as my be just and equitable in the premises.

Manila, Philippines, April 2020

VERIFICATION

I, Maria Reyes, I am the plaintiff who caused the above complaint to be

filed and the allegations therein are true and correct.

Maria Reyes

Subscribed and sworn to before me this 24 th day of April 2020 in the City
of Manila. Affiant has exhibited to me his Res. Cert. No. 89357 issued at Manila
on February 2, 1003.

Rhuvo Dela Cruz

Notary Public
Commission Serial No. 001
Until December 31, 1993
Roll of Attorney 0001
IBP No. 0001/ April 24,2000, Manila
PTR No: 0001/ April 24,2000, Manila
Doc. No. 1;
Page No. 2;
Book No. 3;
Series of 2020.