REPUBLC OF THE PHLPPNES

COURT OF FRST NSTANCE OF QUEZON CTY

DEMME R. ROMERO
Plaintiff,

--- versus ---

MARA F. GUAN Defendant



C O M P L A N T

PLANTFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, and resident of 1154 Carola St., Samapaloc, Metro,
Manila; defendant is also a Filipino, of legal age and resident of 1234, Don Quijote St.,
Sampaloc, Metro Manila where he may be served with summons and other processes.

2. Sometime in August 1996 and over a period of six (6) months, defendant borrowed
certain amounts from plaintiff. Defendant promised to pay these amounts on an installment
basis monthly. These amounts now total Five Hundred Thousand Pesos (P500,000.00).

3. Despite repeated demands, both oral and written, defendant failed or has refused to
pay any amount to plaintiff as no installment payment has even been made. A copy each of
plaintiff's two (2) demand letters is attached as ANNEX A and B.
4. Resort to the Baranggay Conciliation process proved fruitless as defendant failed to
appear, despite notice on him to appear. Thus, a Certification to File Action, a copy of which is
attached as ANNEX C, was issued by the Baranggay Chairman.

5. Defendant's obligation is due and demandable and plaintiff is entitled to the payment
of the entire amount of Nine Hundred Thousand Pesos (P900,000.00) plus legal interest.

6. By reason of defendant's unreasonable failure or refusal to pay his due and
demandable obligation, plaintiff was forced to engage the services of counsel to vindicate his
rights thereby committing himself to pay legal expenses amounting to Sixty Thousand Pesos
(P60,000.00).

HEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision
directing defendant to pay him FVE HUNDRED THOUSAND PESOS (P500,000.00), with legal
interest, as ACTUAL DAMAGES and SXTY THOUSAND PESOS (P60,000.00) as Attorney's
Fees.]

Other just and equitable reliefs are also prayed for.

Quezon City for Makati; ______________.

(SGD.) DOREEN GRACE R. FERMN

ttorney for plaintiff
Ateneo Law School, Rockwell
Makati


REPUBLC OF THE PHLPPNES)
City of Quezon ) ss.

D. R.ROMERO, being first sworn, has read the foregoing Complaint and knows the
contents thereof; and that the facts there stated are true.

D.R. ROMERO

Subscribed and sword to before me this 2
nd
day of September, 2001. Affiant exhibited to
me this Residence Certificate No. xxxxxxxx, issued at Quezon City on the nth day of
Month, 2011.

Notary Public
Until December 25, 2011

Doc No.
Page No.
Book No.
Series of 2011