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REPUBLIC OF THE PHILIPPINES

REGIONALTRIALCOURT OF BATANGAS
FOURTH JUDICIAL REGION
BRANCH_____
BATANGAS CITY
KRIS DE LAS ALAS,
Plaintiff.
--versus--

CIVIL CASE NO. ____________

BEA GONZAGA,
Defendant.
x------------------------------------------x

For Collection of Sum of Money

COMPLAINT
PLAINTIFF, thru counsel, to this Honorable Court respectfully alleges that:
1. Plaintiff is of legal age, single, and presently resides at 14 Joey Street, Sta.
Rita, Batangas City where she can be served with summons and other court processes;
while defendant Bea Gonzaga is likewise of legal age and presently resides at John
Street, San Jose, Batangas at which address defendant can be served with summons and
other court processes;
2. On 12 December 2011, plaintiff granted a loan to defendant amounting to
EIGHT HUNDRED THOUSAND PESOS (P 800,000.00) which defendant promised to
pay within a period of one year in TWELVE (12) equal monthly installments with
stipulated interest at the rate of FIVE (5%) percent per month as evidenced by and in
accordance with the terms and conditions of the promissory note executed by defendant,
copy of which is hereto attached as Annex A and made integral part hereof by
reference;
3. Of the said principal obligation, defendant has not made any payment and as of
12 June 2014, the total amount due on the loan account is EIGHT HUNDRED AND
NINETY-NINE THOUSAND NINE HUNDRED AND NINETY-NINE PESOS 98/100
(P 899,999.98), including interests;
4. Payment of said obligation is long overdue, but defendant has failed and
refused, and still fail and refuse to pay the same or any part thereof, notwithstanding
repeated demands from the plaintiff;
5. The instant case is not covered by the Katarungang Pambarangay Law;
6. On account of the defendants unjustified refusal to satisfy plaintiffs valid, just
and demandable claim, the latter was compelled to engage the services of counsel and
incur litigation expenses in the sum of EIGHTY-NINE THOUSAND NINE HUNDRED
AND NINETY 10/100 (P 89,999.1) equivalent to ten percent (10%) of the total amount

due which defendant has expressly agreed to pay under the terms of the promissory note
(Annex A).
PRAYER
WHEREFORE, plaintiff respectfully prays of this Honorable Court that judgment
be rendered ordering defendant to pay the plaintiff:
1. The sum of EIGHT HUNDRED AND NINETY-NINE THOUSAND NINE
HUNDRED AND NINETY-NINE PESOS 98/100 (P 899,999.98), plus daily interest of
ONE HUNDRED AND ELEVEN PESOS 11/100 (P 111.11), from 13 June 2014 until
complete payment is made;
2. The sum of EIGHTY-NINE THOUSAND NINE HUNDRED AND NINETY
10/100 (P 89,999.1), as attorneys fee and expenses of litigation; and
3. The costs of this suit.
Plaintiff also prays for such other relief or remedy as the Honorable Court may
deem just and equitable in the premises.
Batangas City, 9July 2014.
(SGD.) NOLI SANCHEZ
Counsel for Plaintiff
304 MVL Bldg.
P. Burgos St.
Batangas City

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING


I, KRIS DE LAS ALAS, of legal age, after having been duly sworn in accordance with
law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are true and correct of my
personal knowledge and/or on the basis of copies of documents and records in my
possession;
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;

5. To the best of my knowledge and belief, no such action or proceeding is pending in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;
6. If 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 undertake to report that fact within five (5) days therefrom to this Honorable Court.
WITNESS WHEREOF, I hereunto set my hand this 9 th day of July, 2014 at
Batangas City.

(SGD) KRIS DE LAS ALAS


Affiant
SUBSCRIBED AND SWORN TO before me this 9 th day of July, 2014 at
Batangas City; affiant having exhibited to me her CTC No. 1434456 issued on 9
February 2014 at Batangas City.
(SGD.) NOLI SANCHEZ
Notary Public
Until 31 December 2014
PTR No. 123456 / 01-04-14 / Batangas City
IBP No. 123456 / 01-17-14 / Batangas City
MCLE Compliance No. IV
123456 / 18 June 2014
Roll No. 123456
Doc. No. 3
Page No. 45
Book No. VI
Series of 2014