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COMPLAINT FOR DAMAGES BASED ON CONTRACT

(Caption and Title)

COMES NOW the plaintiff by the undersigned attorney, and unto this Honorable Court,
respectfully alleges:

1. That plaintiff ____Mr. Plain___ of legal age and a resident of


_____________________ and defendant _____Mr. Def_______ is likewise of legal
age and a resident of _________________________________.

2. That, on ____date1_____, plaintiff entered into a contract with defendant


whereby the latter, as building contractor, bound himself to construct for the former
a ___poker house__ on a lot identified as No.
_________address___________________, Philippines.

3. That, in paragraph ____ of the Building Contract between plaintiff and defendant,
complete copy of said contract having been attached hereto as Annex "A", it is
provided that the construction of the aforementioned ___poker house__ shall be
terminated, in accordance with contract specifications, on or before
____date2_____, and that, in case of failure on the part of the defendant to finish
said construction within the stipulated period, he is bound to pay plaintiff, as
damages, the sum of Php _____ amount2______ for every day after
____date2_____ until the movie house is completed as per contract.

4. That defendant failed to finished the construction above mentioned on


____date2_____, but he did succeed in finishing the same on the evening of
____date3_____, or a total of __ days after the deadline specified in the contract.

5. That plaintiff had made demands for the payment of damages amounting to Php
____ amount1_______, corresponding to the above mentioned __ days laps, at the
rate of Php ____amount2_______ per day, but defendant failed and refused, and
still fails and refuses, without any justifiable cause or reason, to pay said amount to
plaintiff.

WHEREFORE, it is respectfully prayed that judgment be rendered:

1. Ordering defendant to pay to plaintiff the sum of Php _____ amount1______,


plus interest thereon, at the legal rate from the date this complaint was filed until
the amount is paid;

2. __________Costs___________________. _________other reliefs__________.

_______________________ ___________ ___________________________


Place Date Signature

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