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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
QUEZON CITY, BRANCH 14
AMANDO S. ROBILLO
Plaintiff,

vs.

CIVIL CASE No. 71234


FOR: COLLECTION OF
SUM OF
MONEY, ATTORNEYS
FEES AND OTHER
RELIEFS

JOSHUA D. CELDRAN,
Defendant
x---------------------------------x

COMPLAINT

Comes now the plaintiff, by counsel and before this Honorable Court, most
respectfully states:
PARTIES
1. That plaintiff is a Filipino, of legal age, single and residing at 13-D block,
Carmela Homes, Fairview, Quezon City,
2. That defendant is likewise a Filipino, of legal age, single and residing at
#412 Maginhawa St. Barangay Teachers Village East, Quezon City , at which

addresses the parties herein may be served with summons and other court
processes;
FIRST CAUSE OF ACTION
3. That defendant is indebted to the plaintiff in the amount of one million
pesos (P 1, 000,000.00), the same being the evidence by a promissory note
executed by said defendant on August 11, 2014, certified Xerox copy of
which is attached herein marked as Annex A and made integral part
hereof;
4. That the obligation of one million pesos (Php 1,000,000.00) was to be
paid on or before August 11, 2015 with the interest rate at 12% per annum.
5. That actually the loan was obtained by defendant much earlier that
August 2014 and was used as additional capital of his buy and sell business
of used cars and because of the close friendship between the parties.
6. That the buy and sell of used cars of the defendant have reportedly
suffered reverses and bankruptcy. Moreover, the defendant is reportedly
disposing his properties or about to do so with intent to defraud their
creditors.
7. That despite the lapse of the period, the defendant failed to pay the
amount subject of the promissory note.
8. That the obligation of the defendant together with interest now amounts
to one million and three hundred twenty thousand (Php 1, 320,000.00)
SECOND CAUSE OF ACTION
9. That On October 20, 2014, the plaintiff and the defendant entered into a
loan agreement whereby the defendant borrowed from the plaintiff the
sum of Three Hundred Thousand Pesos (Php300, 000.00) which became due on
December 15, 2014. A copy of the notarized acknowledgement of debt by
the defendant is hereto attached as Annex B;

10. That defendant failed and refused and still continues to fail and refuse
to pay his obligation aforementioned, leaving the plaintiff with no other
alternative but to institute the present action for the collection of said
obligation.
11. The plaintiff sent separate demand letters to the defendant on October
15, 2015 and January 15, 2016 for the fulfillment of the obligations subject
of the promissory and loan contract.
PRAYER
WHEREFORE, it is respectfully prayed of this Honorable Court that be
rendered in favor of the plaintiff and against defendant ordering him
a. To pay the plaintiff amount of one million and three hundred twenty
thousand pesos (Php 1,320,000.00) as of February 2015 and any and all
interest acquiring thereon at the stipulated rate of 12% per annum until the
obligation is paid in full;
b. That the total amount of the promissory note and the loan contract, with
interest thereon at the legal rate of 12% per annum from the time of the
filing of the complaint and until the same is fully paid
b. To pay the plaintiff the amount of Thirty Thousand Pesos (Php 30,000.00)
as acceptance fee for counsel plus One Thousand Five and Hundred Pesos
(Php 1, 500.00) for every appearance of counsel in court and 25% percent
of the total amount recovered as attorneys fees;
c. To pay the plaintiff amount of Thirty Thousand Pesos (Php 30,000.00) as
litigation expense, plus costs.
Plaintiff respectfully asks this Honorable Court to issue an order of
attachment on the property of the defendant listed hereinabove for the
satisfaction of any judgment in favor of the plaintiff.
Plaintiff further prays for any and all such other reliefs as may be just and
equitable under the premises.

ATTY. LOISE ALMAY G JUGUAN


Counsel for Plaintiff
S.C. Roll of Attorneys No. 542
IBP Life Member No. 631
PTR No. / / Taguig City
MCLE Compliance No. 1111;
Makati City
Contact Nos. 09152998803
Email address: Loisejuguan@gmail.com

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING


I, Amando Robillo, of legal age and with address at 13 D block Carmela
Homes, Fairview, Quezon City after having been duly sworn to in
accordance with law, hereby states that:
1. I am the complainant in the foregoing complaint;
2. I have prepared or caused the preparation of the foregoing complaint;
3. I have read and understood the same and that all the allegations
contained therein are true and correct based on my own personal
knowledge and/or authentic records;
4. I have not commenced any other action or proceeding involving the
same issue/s and subject matter/s in the Supreme Court, the Court of
Appeals, any inferior court, or any other tribunal, quasi-judicial office or
agency; and to the best of my knowledge, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, any inferior court, or
any other tribunal, quasi-judicial office or agency.
5. If I should learn thereafter that a similar action or proceeding has been
filed or is pending in the aforementioned courts, tribunal or agency, I shall

inform this Honorable Court of such fact within five (5) days from notice or
knowledge of the same.
In WITNESS WHEREOF, I have hereunto set my hand this 12th day of
February 2015 at City of Quezon, Philippines.

________________
Complainant/Affiant

SUBSCRIBED AND SWORN to before me this 12TH day of February at


Quezon City, Philippines. I further certify that I personally examined the
affiant and that I am fully satisfied that she understood the foregoing
statements and that he/she had voluntarily and freely executed the same.

Doc. No. 0005;


Page No. 1258;
Book No. 1111;
Series of 2015.

ANNEX A
PROMISSORY NOTE Php1, 000,000.00 , Quezon City, Philippines, August
11, 2014 FOR VALUE RECEIVED, I promise to pay to the order of one million pesos
(Php1,000, 000.00) at his residence 13 D Block, Carmela Homes, Fairview,
Quezon City August 11, 2015
______________________
Maker

ANNEX B
ACKNOWLEDGEMENT OF DEBT
KNOW ALL MEN BY THESE PRESENTS:
I, Joshua Celdran, Filipino, of legal age, single, with postal address at #412
Maginhawa St. Barangay Teachers Village East, Quezon City ,witnesseth:
That I am indebted in the sum of THREE HUNDRED THOUSAND
PESOS(P300,000.000), Philippine Currency, to Amando Robillo, also a
Filipino, of legal age, single, with postal address at D block, Carmela Homes,
Fairview, Quezon City; That I shall pay the sum of THREE HUNDRED
THOUSAND PESOS (Php 300,000.00) unto Amando Robillo on or before
December 15, 2014. IN WITNESS WHEREOF I have affixed my signature
hereto this 15th day of July 2014 in Quezon City, Philippines
WITNESSES:
_____________________________ _______________________________
CHOLO PASCUAL
RUBY ANN SANTOS

ACKNOWLEDGEMENT
REPUBLIC OF THE PHILIPPINES

BEFORE ME, a Notary Public, this 15th day of July 2014 personally appeared
the following:
Name
CTC Number
Date/Place/Issued
Joshua Celdran
1000000
October 15, 2014 Quezon City
Amando Robillo 1000000
January 15, 2014 Quezon City
WITNESS WHEREOF, I have hereunto set my hand the day, year and place
above written.
Loise Almay G. Juguan
Notary Public

Doc. No. 11
Page No. 17
Book No. III
Series of 2014