Republic of the Philippines

REGIONAL TRIAL COURT

9TH Judicial Region
Branch 22
RAY COOPERATIVE,
Plaintif,

CIVIL CASE No. 72590

For the COLLECTION OF
SUM OF MONEY

- versusLA,
Defendant.
x- - - - - - - - - - - - - - - - - - - - - - -x
COMPLAINT-AFFIDAVIT
COMES NOW the plaintiff by the undersigned attorney, and unto this
Honorable Court, respectfully manifest:
1. That plaintiff Ray Cooperation is a cooperation duly organized and
existing under the Laws of the Republic of the Philippines, engaged in
the business of loan transaction located at Cagayan de Oro City
2. That defendant LA is of age, married, a Filipino citizen and a resident of
Sheker Avenue, Barangay San Miguel, Iligan City, and may be served
with summons, writs and all orders of the Honorable Court at his office
address at Iligan City, Philippines;
3. That on October 31, 2007, defendant borrowed Three Hundred Fifty
Thousand pesos (P 350,000.00) from plaintiff payable on or before
October 31, 2008 and as security for the payment, defendant executed
a promissory note is attached hereto and made an integral part hereof
as Annex A;
4. That despite demands, both verbal and written, made upon defendant,
the latter failed and refused and continuously refused to pay his lawful
obligation;
5. As a result of defendants breach of obligation to pay his indebtedness
and being compelled to litigate, plaintiff was obliged to hire services of
a lawyer who is entitled to attorneys fees in an amount of ONE

HUNDRED FIFTY THOUSAND PESOS (P150,000.00), which should be

assessed against defendant.
WHEREFORE, IN VIEW OF ALL THE FOREGOING, plaintiff through counsel
prays this Honorable Court, after due hearing, to adjudge defendant LA to pay
the following:
(1) Principal loan
(P350,000.00);

of

THREE

HUNDRED

FIFTY

THOUSAND

PESOS

(2) Attorneys fees and litigation expenses with legal interest from the date
of filing his suit, plus costs of the suit, and such other remedies as may
be just and equitable in the premises in the sum of ONE HUNDRED
FIFTY THOUSAND PESOS (P150,000.00).
Cagayan de Oro City, December 18, 2008.

CRYSTAL Y. PACAS
Roll No. 76137
IBP LIFE MEMBER No. 1111035
PTR No. 9110129, July 25, 2009
MCLE COMPLIANCE III No. 0025810, March 21,
2010
COUNSEL FOR THE PLAINTIFF