Republic of the Philippines

REGIONAL TRIAL COURT

Ninth Judicial District
Branch 14
Zamboanga City

ROBB M. SANDOVAL,
Plaintiff

CIVIL CASE NO. 13335

-versus- FOR : COMPLAINT FOR
SUM OF MONEY

SANDOR B. CARBONELL,
Defendant,
x-----------------------------------x

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff Robb M. Sandoval (hereafter Plaintiff ) is a Filipino
citizen, of legal age, married and residing at Banilad, Zamboanga City where
he may be served with court processes, motions, and decision;

2. Defendant Sandor B. Carbonell (hereafter Defendant) is a Filipino

citizen, of legal age, and residing Talamban, Zamboanga City where he may
be served with summons and other court processes;

3. That on August 1, 2014, defendant executed a promissory note in

favor of the plaintiff in the amount of P500,000 payable within 30 days from
the date of the promissory note (attached as ³Annex A´) which reads as
follows:
Zamboanga City, Philippines
1 August 2014

I promise to pay Robb M. Sandoval the sum of P500,000 or order

within30 days from this date.

Sandor B. Carbonell
 4. That the 30-day period had elapsed and despite demands made
orally and in writing (attached as ³Annex B´) by the plaintiff, defendant
refused and failed to pay the amount stated in the promissory note;

5. That due to the unjust refusal of defendant to comply with the

demands, plaintiff was compelled to file the instant action engaging the
services of counsel in the amount of P10,000.00.

PRAYER
WHEREFORE, plaintiff respectfully prays for judgment in his favor
through a Decision directing defendant to pay him FIVE HUNDRED
THOUSAND PESOS (P500, 000.00), with legal interest, as ACTUAL
DAMAGES and TEN THOUSAND PESOS (P10, 000.00) as Attorney’s
Fees.
Plaintiff prays for such other and further reliefs as may be just and
equitable reliefs
Zamboanga City, June 29, 2020

ATTY. KHAL DROGO A. LA GUARDIA

Counsel for the Plaintiff
Until December 21, 2020
PTR No. 12345; Zamboanga City; 1/3/2020
Roll of Atty. No. 21435
IBP No. 06785
Dragon’s Lair, Zamboanga City

REPUBLIC OF THE PHILIPPINES )

CITY OF ZAMBOANGA ) S.S.

VERIFICATION AND CERTIFICATIONOF NON-FORUM

SHOPPING

I, Robb M. Sandoval, Filipino, of legal age, after been duly sworn,

depose and state that:
I am the Plaintiff in the forgoing Complaint for Sum of Money.
I caused the preparation of the foregoing Complaint which I have read
and understood.
 I hereby affirm that all factual allegations contained in the said
Complaint are true and correct of my own personal knowledge and belief, as
well as true and correct basis of authentic documents and records in my
possession.
I further certify that I have not commenced any other action involving
the same issues before the Supreme Court, Court of Appeals or any division
thereof or any tribunal or agency; and to the best of my knowledge no such
action is pending before the Supreme Court, Court, Court of Appeals or any
division thereof or any tribunal or agency.
In the event that any action involving the same should be made
known, I hereby bind myself to report the same within five (5) days from
knowledge thereof to this Honorable Court.
WITNESS WHEREOF, I hereunto set my hand this 14th day of
December, 2014 at Zamboanga City, Philippines.

ROBB M. SANDOVAL
Plaintiff

SUBSCRIBED AND SWORN TO before me this 29th day of June at

Zamboanga City, affiant having exhibited to me her CTCNo.133143364
issued on January 22 at Zamboanga City.

Doc. No. xx;

Page No.xx;
Book No. xx;
Series of 2020.