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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF MANILA


National Capital Judicial Region
Branch ____, Iloilo City
Alexander Sison,
Plaintiff,

Civil Case No. _____


For: Collection of Sum of
Money with Prayer of
writ for the issuance of
Preliminary Attachment

-versusJuan Jamero,
Defendant.
x------------------------------------------x
COMPLAINT
PLAINTIFF, through counsel, most respectfully avers:

(1.)

That plaintiff, Alexander Sison is a Filipino citizen, of


legal age, single and a resident of 111 Libertad St.
Sampaloc Manila, whereas, defendant Juan Jamero is
likewise a Filipino, of legal age, single, and residing at
222 Juan Luna St., Tondo Manila, at which address the
party herein may be served with summons and other
court processes;

(2.)

That on January 3, 2008, defendant borrowed from


plaintiff the amount of one million pesos (Php.
1,000,000.00) , which indebtedness is due and payable
on or before January 3, 2009, with an interest at the
rate of 12% per annum within one (1) year, in
accordance with the promissory note executed by the
defendant on the said date. Photostatic copy of said
promissory note is attached and marked as Annex A
and made as a integral part hereof;

(3.)

That the defendant has failed and refused and still fails
and refuses to pay the said indebtedness on due date,
with corresponding interest thereon to the herein
plaintiff, despite repeated requests and demands.

(4.)

That the plaintiff served several demands to the


defendant, attached is the last demand letter executed
on July 01, 2009 by the plaintiff as annex B and
made as an integral part hereof;

(5.)

That the defendant shall pay for the attorneys fees and
expenses of litigation in the amount of Php. 75,000.00
and a fee of P3,000 for every appearance in court, and
to pay the cost of this suit;

(6.)

That the plaintiff is willing to put up a bond for the


issuance of a preliminary attachment in an amount to
be fixed by the court, not exceeding the sum of one
million pesos which is the plaintiffs claim herein;

Allegations for the Issuance of for Preliminary Attachment


Plaintiff further states and alleges:
(7.)

That Plaintiff has a valid and sufficient cause of action


against the herein defendant regarding the collection of
sum of money which is already due and demandable;

(8.)

Defendant has removed or disposed of or is about to


remove or dispose of her property, with intent to
defraud her creditors thereby rendering nugatory and
ineffective whatever money judgment this honorable
court may render in the above entitled case;
That the defendant does not have sufficient security for
the claim sought for the plaintiff against him;

(9.)
(10.)

That the plaintiff is willing to put up a bond for the


issuance of a preliminary attachment in an amount to
be fixed by the court, not exceeding the sum of one
million pesos which is the plaintiffs claim herein;

PRAYER
WHEREFORE, it is most respectfully prayed of this
Honorable Court that pending hearing of this case a
writ of preliminary attachment be issued against the
property of the defendant to serve as security for the

satisfaction of any judgment that may be recovered


herein; and that after due hearing on the principal cause
of this action, judgment be rendered against the
defendant for the sum of the following:
(1.) Ordering defendant to pay plaintiff the amount of one
million pesos (Php. 1,000,000.00) plus interest thereon
at the rate of 12% per annum from January 3, 2009,
and until the same is fully paid; and
(2.) Ordering defendant to pay the attorneys fees and
expenses of litigation in the amount of Php. 75,000.00
and a fee of P3,000 for every appearance in court, and
to pay the cost of this suit;
Plaintiff likewise prays for such other and further relief
or reliefs as this Honorable Court may deem just and
equitable under the premises.
Manila, Philippines, September 01, 2009.

MARY JOY S. DEJADA


Counsel for the Plaintiff
4321 suite, Makati Manila

REPUBLIC OF THE PHILIPPINES)


MANILA PHILIPPINES) S.S.
x-------------------------------------------x

VERIFICATION AND CERTIFICATION OF NON-FORUM


SHOPPING
I, Alexander Sison,Filipino, of legal age, single, after having been
duly sworn in accordance with law, deposes and states that:
1. That I am the plaintiff in the above-stated case;
2. That I have caused the preparation of the foregoing complaint;
3. I have read and understood the allegations therein contained
and the same are true and correct of my own personal
knowledge and based on authentic records;
4. I have not commenced any other action or proceeding
involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency; to the best of my
knowledge and belief, no such action or proceeding has been
filed or is pending before the Supreme Court, the Court of
Appeals, or other tribunal or agency; that I should thereafter
learn that a similar action or proceeding has been filed or is
pending before the Supreme Court , the Court of Appeals, or
any other tribunal or agency, I under take to report that fact
within five (5) days therefrom to this Honorable Court.
IN WITNESS WHEREOF, I have hereunto set my hand this
1st day of September, 2009 in Manila, Philippines.

SisonAlexander
Alexander Sison
Affiant
SSS ID no. 1234567
Issued at: Manila,
Philippines
Issued on: January 09,
2006

SUBSCIBED AND SWORN TO before me this 1st day of


September, 2009, in Manila after showing to me his competent
evidence of identity indicated below his name.
I HEREBY CERTIFY that I personally examined the
affiant and I am satisfied that she voluntarily executed and
understood his declaration on the place and date above written.

ATTY. MARY JOY S. DEJADA


Notary Public
Commission No.00145
My Commission expires on December
31,2008
Until 31 December 2008
Law office address: Jaro, Iloilo City
Roll of Atty.s No.: 08667
PTR No. 8978978
Issued on December 26, 2005
Issued at Iloilo City, Philippines
IBP No.879879
Issued on December 29, 2005
Issued by: IBP-Iloilo Chapter
MCLE Compliance No1-0000066
Date Issued: January 3, 2006
Doc. No. 1_
Page No2
Book. No. I
Series of 2009
Date and Time Notarized: __________

ANNEX A

PROMISSORY NOTE
ANNEX A
Promissory Note

January 03, 2008


Manila, Philippines

Php. 1,000,000.00
For value I received, I promise to pay to the order of Alexander Sison the sum of
One million pesos (Php. 1,000,000.00) with 12% interest per annum on or before
January 03, 2009, at his house in 111 Libertad St., Sampaloc, Manila.

JJamero
Juan Jamero

ANNEX B
DEJADA AND ASSOCIATES

Lawyers and Notary Public


4321 suite, Makati Manila, Philippines
DEMAND LETTER
July 01, 2009
Mr. Juan Jamero
222 Juan Luna St., Tondo, Manila
Dear Sir:
Our client Alexander Sison had referred to us his case as regards to
your indebtedness amounting to One million Pesos (Php. 1,000,000.00).
Please be reminded that your promissory note has become due on
January 03, 2009 and a demand letter was sent last March 01, 2009.
Kindly make necessary payments to our client on or before 4 pm on
August 01, 2009. The refusal to accede to this second and final demand
letter will prompt the undersigned to seek recourse before the courts of
law.
Please give this matter your utmost and preferable attention.

ATTY. MARY JOY S. DEJADA


Counsel for the Plaintiff