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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


National Capital Judicial Region
Branch 109, Pasay City

Marvin Chang Chua,


Plaintiff.

-versus- CIVIL CASE No. 123456


FOR: COLLECTION OF
SUM OF MONEY
__________________,
Defendant.

x------------------------------------------------------------x

COMPLAINT

Plaintiff, through counsel, and unto this Honorable Court respectfully states that:

1. Plaintiff is of legal age, single, Filipino, and resident of 2600, Jose Abad
Santos Avenue, Tondo, Manila where summons and court processes may
be served;

2. Defendant is also of legal age, single, Filipino, and resident of


_______________________ where summons and court processes may be
served;

3. On September 1, 2017, Defendant obtained a loan from Plaintiff in the


amount of One Million Pesos (P1,000,000.00), as evidenced by a
PROMISSORY NOTE, a photocopy of which is attached as “Annex A” and
form an integral part of this complaint;

4. As shown in the attached promissory note, the indebtedness of the


Defendant has become due and demandable on October 1, 2017;

5. Despite the repeated demands of the Plaintiff both verbal and written, the
Defendant failed, and still refuses to comply with his obligation to settle and
pay the said amount. The photocopies of Plaintiff’s demand letters are
attached as “Annex B”, “Annex C”, and “Annex D”, and form an integral part
of this complaint;

6. The said loan is now long overdue, thus, in order to protect and enforce his
rights, Plaintiff has sought the services of a legal counsel and thus incurred
Attorney's Fees in the amount of Fifty Thousand Pesos (P50,000.00),
And litigation expenses in the amount of Five Thousand Pesos (P5,000.00).
PRAYER

WHEREFORE, premises considered, it is respectfully prayed before the Honorable


Court to render a decision in favor of the Plaintiff and to order the Defendant to pay:

a) The sum of ONE MILLION PESOS (P1,000,000.00); and

b) Attorney’s Fees and Cost of this suit.

Other reliefs and remedies deemed just and equitable under the foregoing premises
are likewise prayed for.

Pasay City, Philippines, 26thJanuary, 2018.

ATTY. MARIEFLOR BATTUNG


Counsel for Plaintiff
Battung Law Office Unit 36 Alterra Bdg., Pasay City
Roll of Attorneys No. 54312
PTR No. 123654, 1/6/2018
IBP No. 789654, 1/6/2018
MCLE Compliance No. IV-009878, 1/2/2018
REPUBLIC OF THE PHILIPPINES)
PASAY CITY ) SS.
x----------------------------------------------------x

VERIFICATION AND CERTIFICATION

That I, Marvin Chang Chua, of legal age, single, Filipino, and resident of 2600,
Jose Abad Santos Avenue, Tondo, Manila after having been duly sworn in accordance
with law, hereby depose and say that:

1. I am the Plaintiff in the above entitled case;

2. That I have caused the preparation of the above complaint and I have read
the same and understood the contents thereof;

3. That the allegations contained therein are true and correct to the best of my
knowledge and based on authentic records;

4. I did not commence any action or filed any claim involving the same issues
in any court, tribunal, or quasi-judicial agency and, to the best of my
knowledge, no such other action or claim is pending in them; and

5. If I should learn that the same or similar action or claim has been filed or is
pending after its filing, I shall report that fact within five (5) days from notice
to the court or where the complaint or initiatory pleading has been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 26th of


January, 2018 at Pasay City.

Marvin Chang Chua


Affiant
Driver’s License #N04-05-005243
SUBSCRIBED AND SWORN to before me this 26th day of January 2018, affiant
exhibiting to me his Driver’s License as shown above below his name as competent
evidence of his identity.

ATTY. MARIEFLOR BATTUNG


NOTARY PUBLIC
Commission Serial No. 231
Until Dec. 31, 2019
Battung Law Office Unit 36 Alterra Bdg., Pasay City
Roll of Attorneys No. 54312
PTR No. 123654, 1/6/2018
IBP No. 789654, 1/6/2018
MCLE Compliance No. IV-009878, 1/2/2018

Doc No.:23
Page No.:5
Book No.: 8
Series of 2018.