REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT OF MANILA MANILA, BRANCH 2

JUAN CRUZ, Plaintiff, Civil Case No. 07-123456 --- versus ---FOR: SUM OF MONEY AND DAMAGES JOHN REYES, Defendant.

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COMPLAINT

COMES NOW the plaintiff, through the undersigned counsel, respectfully states that: 1. Plaintiff Juan Cruz is a Filipino citizen, 27 years old, married to Carla Cruz and residing at 8 Marwood St., Taft, Manila, where he may be served with orders and other processes of this Honorable Court ; 2. Defendant John Reyes is a Filipino citizen, 27 years old, single, and residing at 10 Bridgestone Park, Taft, Manila, where he may be served with summons and other processes of this Honorable Court ; 3. On February 28, 2012, defendant went to the residence of the plaintiff at 8 Marwood St., Taft, Manila to borrow money amounting to P650,000.00. 4. Upon receipt of said amount, defendant executed a promissory note in favor of the plaintiff payable within 30 days from the date of the promissory note (attached as Annex A ) which reads as follows:

Manila, Philippines February 28, 2012 I, promise to pay Juan Cruz the sum of P650,000.00 or order within 30 days from this date.

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John Reyes 5. The 30-day period had elapsed and despite demands made orally and in writing (attached as Annexed B) by the plaintiff, defendant refused and failed to pay the amount in the promissory note. 6. Due to the unwarranted refusal of the defendant to pay his valid obligations to plaintiff, the latter suffered social humiliation, wounded feelings, sleepless nights and serious anxiety, defendant should be ordered to pay plaintiff moral damages in the sum of P30,000.00 and ; to show example to the public of his wrongful act, defendant should pay plaintiff the sum of P20,000.00 as exemplary damages; 7. 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 P20,000.00.

PRAYER WHEREFORE, the plaintiff respectfully prays for judgment in his favor through a decision directing defendant to pay him SIX HUNDRED FIFTY THOUSAND PESOS (P650,000.00), with legal interest, as ACTUAL DAMAGES; THIRTY THOUSAND PESOS (P30,000.00) as MORAL DAMAGES; TWENTY THOUSAND PESOS (P20,000.00) as EXEMPLARY DAMAGES and TWENTY THOUSAND PESOS (P 20,000.00) as Attorneys Fees.

Other just and equitable reliefs are also prayed for. Manila, Philippines, March 25, 2012.

Ira Santos Counsel for Plaintiff nd 2 Floor, RC Bldg, Taft Manila PTR No. 123456/Manila/January 10, 2009 IBP No. 123456/Manila/January 20, 2009 Roll of Attorneys No. 123456 MCLE Compliance No. 123456 1/3/2012 Tel No. 123456

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VERIFICATION WITH CERTIFICATION OF NON-FORUM SHOPPING

I, Juan Cruz, subscribing under oath, hereby depose and state, that: 1. I am the plaintiff in the above-entitled case, and I have caused the preparation of the said complaint; 2. I have read the foregoing Complaint and the allegations therein are true and correct based on my personal knowledge; 3. I attest to the authenticity of the annexes thereto; 4. I have not commenced any other action or proceeding involving the same issues in the Supreme Court, Court of Appeals, or different divisions thereof, or any other tribunal or agency; 5. No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency; 6. If I should learn thereafter that a similar action or proceeding has has been filed or is pending before the Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or agency, I hereby undertake to notify this Honorable Court within five (5) days from such notice. Juan Cruz Plaintiff SUBSCRIBED and SWORN to before me this 25th day of March 2012, in Taft, Manila. The affiant exhibiting to me his SSS No. N26-01-004190 issued by Social Security System, on May 12, 2001 and Drivers License No. 12345678 issued on November 30, 2010 at Taft, Manila. Atty. Don De Leon Notary Public for Manila #45 Burgos St., Taft, Manila Roll of Attorneys No. 12345 PTR No. 123456 01/10/08 IBP No. 56789123 01/28/02 MCLE Compliance No. 1-002746 Doc. No. 1 Page No. 2 Book No. 3 Series of 2012
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