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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
City of Mandaluyong
Branch 1
PAUTANG INCORPORATED
represented by Asiong Aksaya,
President,
Plaintiff,
CIVIL CASE No. 0001
FOR: Collection of sum
of money

-versusGARY GASTOS,
Defendant.
x-----------------------------------x
COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and
unto this Honorable Court, most respectfully avers:
1.
That the plaintiff, is a finance and lending corporation duly organized
and existing under the Laws of the Philippines, having its principal office at
68 Shaw Blvd, Mandaluyong City;
2.
That the defendant, GARY GASTOS, is of legal age, Filipino citizen,
single, with residence and postal address at 69 Shaw Blvd, Mandaluyong
City, where they may be served with summons and other court processes;
3.
By virtue of a contract of loan executed June 1, 2013 hereto attached
as Annex "A", the defendant obtained a loan from the plaintiff in the sum of
Eight Hundred Thousand Pesos (P800,000.00) Philippine Currency, with the
following terms and conditions among others:
a. The principal loan obligation shall be payable in 1 year from
the execution of the agreement;
b. The principal shall be paid on installment basis on which there
will be 4 payments of One Hundred Twenty Five Thousand
Pesos (P125,000) and last payment of Four Hundred Twenty
Five Thousand Pesos (P425,000);
c. The 1st payment of the installment amount shall be paid on the
month of September 2013, 2nd payment on December 2013,
3rd payment on March 2014 and the last payment on June
2014;
d. The principal loan obligation shall incur an interest of 10% per
month compounded in the event of delay in payment.
4.

The defendant failed to pay the last installment amount of FOUR
HUNDRED TWENTY FIVE THOUSAND PESOS (P425,000) for the last
payment month of June 2015;

000 payable within 30 days from the date of the promissory note hereto attached as Annex "B" which reads as follows: Mandaluyong. 12345/2-5-12/Antipolo PTR No. To pay the amount of P425. 2014 with interest. after hearing. 2015. 7. plaintiff was compelled to file the instant action engaging the services of counsel in the amount of P50. GARY GASTOS 6. WHEREFORE. premises considered.000. 12345/2-6-12/Antipolo PTR No. January 1. City of Mandaluyong. the sum of P125. judgment be rendered ordering the defendant: 1. Philippines 1 July 2014 I promise to pay PAUTANG INC.000 due last June 30. 00001 IBP No. 00002/ 1/2/2015/Antipolo VERIFICATION/CERTIFICATION OF FORUM SHOPPING . On July 1. Abad Roll of Attorney No. ABAD AND AGRA LAW OFFICE Counsel for the Plaintiff Antipolo City By: La Verne A. To pay the plaintiff the cost of the suit.5. defendant executed a promissory note in favor of the plaintiff in the amount of P 425. 2. That due to the unjust refusal of defendant to comply with the demands.000 or order within 30 days from this date. 87654/12-22-11/Antipolo MCLE Compliance Certificate No. 87654/12-23-11/Antipolo MCLE Compliance Certificate No. defendant refused and failed to pay the amount stated in the promissory note. it is most respectfully prayed unto this Honorable Court that. 00002 IBP No. 2014. 00001/ 1/1/2015/Antipolo By: Jeare Agra Roll of Attorney No. That the 30-day period had elapsed and despite demands made orally and in writing (attached as “Annex C”) by the plaintiff.

6. 12345 12345 Issued on/Issued at June 1 2013/Mandaluyong City June 1 2002/Mandaluyong City ATTY. SSS No. 2015. under oath. tribunal or quasi-judicial agency and. Circular No. 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.Republic of the Philippines ) City of Mandaluyong ) S. __1____ Book No. That I have caused the preparation of the foregoing complaint and have read the allegations contained therein. Mandaluyong City. located at at 68 Shaw Blvd. HIMALA Notary Public My Commission Expires Dec. 2. No. I executed this verification/certification to attest to the truth of the foregoing facts and to comply with the provisions of Adm. I have hereunto affixed my signature this 1st of January 2015. Drivers License 2. to the best of my knowledge. 1. . 31. 2015 Roll of Attorney No. __1____ Series of 2015. 87654/12-22-11/Mandaluyong Doc. 4. in the City of Mandaluyong. no such other action or claim is pending therein. Asiong Aksaya Affiant SUBSCRIBED AND SWORN to before me this 1st day of January. The allegations in the said complaint are true and correct of my own knowledge and authentic records.S. 12345/2-5-12/Mandaluyong PTR No. do hereby depose and state that: That I am the plaintiff in the above-entitled case. 45456 IBP No. IN WITNESS WHEREOF. I. That if I should learn thereafter that a similar action or proceeding has been filed or is pending. in the City of Mandaluyong. President of PAUTANG INC. 0494 of the Honorable Supreme Court. I hereby certify that I have not commenced any other action or proceeding involving the same issues in any court. 3. 5. __1____ Page No. affiant exhibiting to me: ID 1. Asiong Aksaya.