Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 3
Talisay City

Ronald, plaintif,
Case No. 153465

Civil
FOR:
Collection
of
Sum of
Money and
damages

-versusArnold, defendant,
x-----------------------------------------x
COMPLAINT

COMES NOW, plaintif, Arnold, by counsel, and unto this

Honorable Court, most respectfully avers THAT:
1. Plaintif is a Filipino citizen, of legal age, married to
Roma Mae, and residing at Barangay Lawaan II, Talisay City,
Cebu, where he may be served with summons, papers, and
other process of this Honorable Court.
2. Defendant Arnold is a Filipino citizen, of legal age,
married to Jenniveve, and residing at Barangay Tisa, Cebu
City, Cebu, where he may be served with summons, papers
and other process of this Honorable Court.
3. Sometime on February 14, 2000, Arnold approached
Ronald and pleaded to borrow the amount of FIVE HUNDRED
THOUSAND PESOS which he promises to pay within a period
of one year.
4. Due to their friendship, Ronald agreed to grand
Arnold a load and gave him FIVE HUNDRED THOUSAND
PESOS.
5. Upon the advice of a lawyer friend, Ronald asked
Arnold to execute and sign a promissory note specifying the
amount loaned and the one-year maturity date.

6. When maturity date came, Ronald verbally asked

Arnold to pay his indebtedness, as he is in dire need of
money as his silver wedding anniversary to his wife is fast
approaching.
7. Unfortunately, Arnold refused to pay Ronald and
insisted that he be given a period of one year to settle his
indebtedness, as his silver wedding anniversary to his wife is
also approaching.
8. In view of Arnolds refusal to settle his indebtedness,
Ronald was left with no other recourse but to send him a
demand letter requesting him to settle his indebtedness in
the amount of FIVE HUNDRED THOUSAND PESOS (P500,000)
within 10 days from receipt thereof.
9. However, in spite of previous repeated oral and
written demands made by Ronald, Arnold merely ignored the
same and obstinately refused to settle his indebtedness.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed of this Honorable Court that judgment be rendered in
favor of the plaintif and that after judgment;
a. The defendant shall pay the entire debt of five
hundred thousand pesos (Php 500,000.00).
b. Defendants be ordered to pay moral damages in
the amount of FIVE HUNDRED THOUSAND PESOS
(Php 500,000.00);
c. Defendants be ordered to pay attorneys fees in an
amount equivalent to TWENTY FIVE PERCENT
(25%) of the total amount to be adjudged in favor
of plaintifs;
d. Defendants be ordered to pay the costs of this
suit.
Other reliefs just and equitable under the premises are likewise prayed
for.

Such other reliefs and remedies

under the premises are likewise
prayed for.
Talisay City, February 25, 2014.

Atty. Angel Bert Y. Gemparo

Counsel for the Plaintiff
PTR No. 15334260:1-08-15:Talisay City
IBP No, 693095:1-04-07:Cebu City
Roll No. 42481:5-10-97:Pasig, Manila
MCLE Ex. No. 111-000748 1-13-2015
For 3rd compliance
1105 Lower Kabanayan, Bulacao,
Talisay City, Cebu, Philippines

Republic of the Philippines

Talisay City

)s.s

x- - - - - - - - - - - - - - - - - - - - - - - -x

VERIFICATION AND CERTIFICATION AGAINST FORUMSHOPPING

I, RONALD, of legal age, Filipino citizen, married and

resident of Barangay Lawaan II, Talisay City, Cebu, after
having been duly sworn to in accordance with law do hereby
depose and say:
1.

That I am the plaintif in the above-entitled case;

2.

That I have caused the preparation of the foregoing

complaint and have read the allegations contained therein;

3.

The allegations in the said complaint are true and correct of

my own knowledge and authentic records;

4.

I hereby certify that I have not commenced any other action

or proceeding involving the same issues in any court,
tribunal or quasi-judicial agency and, to the best of my
knowledge, no such other action or claim is pending therein;

5.

That if I should learn thereafter that a similar action or

proceeding has been filed or is pending, I hereby undertake
to report that fact within five (5) days therefrom to the court
or agency where the original pleading and sworn certification
contemplated herein have been filed;

6.

I executed this verification/certification to attest to the truth

of the foregoing facts and to comply with the provisions of
Adm. Circular No. 03-83 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this 18th of February 2014, in the City of Manila.
RONALD
AFFIANT
SUBSCRIBED AND SWORN to before me this 18th day of
February, 2014, in the City of Cebu, affiant exhibiting to me
his Drivers License No. G01-05-003849 issued by the Land
Transportation Office on October 9, 2013 at the City of Cebu.

WITNESS MY HAND AND SEAL.

Doc. No. 0012;
Page No. 003;
Book No. 001;
Series of 2015.

Atty. Angel Bert Y. Gemparo

Counsel for the Plaintiff
PTR No. 15334260:1-08-15:Talisay City
IBP No, 693095:1-04-07:Cebu City
Roll No. 42481:5-10-97:Pasig, Manila
MCLE Ex. No. 111-000748 1-13-2015
For 3rd compliance
1105 Lower Kabanayan, Bulacao,
Talisay City, Cebu, Philippines

PROMISSORY NOTE

P__500,000___
FOR VALUE RECEIVED, I promise to pay without need of demand to
the order of __Ronald__, at his office at ___Talisay City_____, the
principal amount of PESOS: _Five Hundred Thousand Pesos only__
(P_500,000_), on or before __FEBRUARY 01, 2001___. In addition to
the foregoing, I promise to pay, without need of demand, starting from
the month of _February 2001__ until this note is fully paid.

__February 14, 2000 __, ___Talisay City___, Philippines.

Atty. Angel Bert Y. Gemparo

Counsel for the Plaintiff
PTR No. 15334260:1-08-15:Talisay City
IBP No, 693095:1-04-07:Cebu City
Roll No. 42481:5-10-97:Pasig, Manila
MCLE Ex. No. 111-000748 1-13-2015
For 3rd compliance
1105 Lower Kabanayan, Bulacao,
Talisay City, Cebu, Philippines