(Complaint for Collection of Sum of Money)

(CAPTION)

COMPLAINT

COMES NOW Plaintiff, by counsel and to this Honorable Court, respectfully

states that:

1. Plaintiff _____________ is of legal age, Filipino, (single / married / widow), and

a resident of _____________, Philippines. For purposes of this action, plaintiff

may be served with all orders, notices, and other processes of this Honorable

Court through the office address of the undersigned counsel indicated below;

2. Defendant _____________, of legal age, Filipino, (single / married / widow), and

may be served with summons and other processes of this Honorable Court at his

last known address at _____________, Philippines;

3. Sometime on _____________, Defendant obtained from and was granted a loan

accommodation by the Plaintiff in the principal amount of

__________________________ (P_____________), Philippine Currency;

4. A true and faithful machine reproduction of the Promissory Note made by the

Defendant on _____________ is hereto attached as Annex "A";

5. As of _____________, Defendant still has an Outstanding Balance to Plaintiff

amounting to __________________________ (P_____________), Philippine

Currency, and has failed and neglected to pay, without just and valid grounds, the

said Outstanding Balance for the aforementioned loan accommodation;

6. Despite Plaintiff's repeated demands, both written and verbal, Defendant failed,

neglected and refused, and continues to fail and refuse to pay and to settle the said
 Outstanding Balance, without just and valid grounds, to the continued damage

and prejudice of Plaintiff;

7. A true and faithful machine reproduction of the Plaintiff's demand letter to

Defendant dated _____________ is hereto attached as Annex "B";

8. Consequently, Plaintiff was constrained to engage the services of counsel to

whom it obligated itself to pay as Attorney's Fees the amount equivalent to

_____________ (______%) percent of the total amount due from Defendant to

Plaintiff.

PRAYER

WHEREFORE, after due notice and hearing, Plaintiff respectfully prays that

judgment be rendered against the Defendant as follows:

1. Ordering the Defendant to pay Plaintiff the sums of:

a. The amount of __________________________ (P_____________),

representing Defendant's Outstanding Balance plus interest at the rate

of _____________ (_____%) per month as stipulated upon in the

Promissory Note;

b. _____________ (_____%) percent of the total amount due as

Attorney's Fees plus Appearance Fee at the rate of P__________ per

court hearing / conference;

c. _____________ (_____%) percent of the total amount due as

Collection Charges / Liquidated Damages;

d. The costs of suit.

2. Plaintiff respectfully prays for such other reliefs as may be just and equitable

in the premises.

Date _____________, Philippines, __Date__.

(COUNSEL)

(VERIFICATION)

(CERTIFICATION OF NON-FORUM SHOPPING)