You are on page 1of 3

Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 29 Makati City

Juan Miguel Dela Cruz, Plaintiff, -versusCivil Case No. 10-221167 FOR: COLLECTION FOR SUM OF MONEY

Jane Rossana Clarice Doe, Defendant, x------------------------------------------------x COMPLAINT P L A I N T I F F , through undersigned counsel, to the Honorable Court, respectfully States the following: most

1. That Plaintiff is a Filipino citizen, of legal age, and residing #629 Avenue, Barangay Pembo, Makati City, where he may be served with court processes, motions, and decision; 2. That Defendant is also a Filipino citizen, of legal age, and residing 10th Avenue, Barangay Central, Quezon City, where she may be served with summons and other court processes; 3. That on January 11, 2004, defendant, Jane Rosanna Clarice Doe obtained a loan from the herein plaintiff Juan Miguel Dela Cruz in the amount One Million Pesos (1,000,000) Philippine Currency. The copy of the promissory note is attached herein as Annex A; 4. That to serve as collateral for the said loan, defendant Jane Rosanna Clarice Doe offered as security a motor vehicle, Toyota Fortuner, and obliged herself to pay the obligation within six (6) months. Copies of the Official Receipt (Or) and Certification of Registration (CR) of the said motor vehicle are hereto marked and attached as Annexes B and C respectively.

5. That despite numerous demand both oral and written, defendant failed and still fails and refuses to pay her obligation in the sum of One Million pesos (1,000,000) Philippine Currency.

6. That Plaintiff was constrained to engage the services of the Undersigned Counsel to protect his rights and interest, and to pay e the sum of Fifty thousand Pesos (50,000) Philippine Currency by way of Attorneys fees.

PRAYER WHEREFORE, premises considered, it is most respectfully prayed on the Honorable court that upon due notice and hearing, Judgment be rendered in favor of the plaintiff: 1. To order the defendant Jane Rosanna Clarice Doe to pay the amount of ONE MILLION PESOS (1,000,000) Philippine Currency representing the amount of her unpaid obligation to herein plaintiff, Juan Miguel Dela Cruz; 2. To order the defendant, Jane Rosanna Clarice Doe, to pay the plaintiff the sum of FIFTY THOUSAND PESOS (50,000) Philippine Currency, as and by way of Attorneys Fee and; 3. To order the defendant, Jane Doe to pay the cost of this suit. Other just and equitable reliefs are also prayed for. Respectfully submitted, Makati City, Philippines, JANUARY 18, 2012.

ATTY. ANNA GRACE NINZ OSORIO -Counsel for the PlaintiffPTR No. 0917889 Issued on: January 24, 2012 Issued at: Far Eastern University, Manila IBP No. 091237 Issued on: January 27, 2012 Issued at: Padre Faura, Manila ROLL No. 12347

VERIFICATION/CERTIFICATION OF NON-FORUMSHOPPING I, Juan Miguel Dela Cruz, after having been duly sworn to in accordance with law, do hereby depose and say:
1. That I, am Juan Miguel Dela Cruz, a Filipino citizen, of legal age, and residing

#629 Avenue, Barangay Pembo, Makati City, where he may serve with court processes, motions, and decision;
2. That I caused the preparation and filing of the foregoing Complaint; 3. That all the allegations therein stated are true and correct to the best of my knowledge

and information;
4. That I did not commence any other action or proceeding involving the same issues in

the Supreme Court, the Court of Appeals or the different Divisions thereof, or any other tribunal or agency;
5. That shall I learn thereafter that a similar action or proceeding has been filed or in

pending before the Supreme Court, the Court of Appeals or any other tribunal or agency, undertake to report that fact within five (5)days to this Court. Respectfully submitted, Makati City, Philippines, JANUARY 18, 2012.

Juan Miguel Dela Cruz CTC No. 12345678 Issued on: January 18, 2012 Issued at: Padre Faura, Manila

SUBSCRIBED AND SWORN to before me this 18th day of January, 2012 at Padre Faura, Manila.

DOC. No. 18ATTY. ANNA GRACE NINZ OSORIO PAGE No.8 NOTARY PUBLIC BOOK No. 888 UNTIL DECMBER 2013 Series of 2012 PTR No. 1243565

Dated: January 18, 2012 Padre Faura, Manila