(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 AND CERTIFICATION

REPUBLIC OF THE PHILIPPINES)

Province of ____________________) S.S.
City/Municipality of _____________)
x-----------------------x

I, _____________, of legal age, Filipino, (single / married / widow), and a resident of

_____________, Philippines, after being sworn in accordance with law, hereby depose and say:

That I am the (Plaintiff / Complainant / Petitioner) in the above-entitled case; That I have
caused the preparation of the above (Complaint / Petition) and I have read the same and knows
the contents thereof; That the allegations contained therein are true and correct of my own
personal knowledge.
 That I further certify that: (a) I have not theretofore commenced any other action or
proceeding or filed any claim involving the same issues or matter in any court, tribunal, or quasi-
judicial agency and, to the best of my knowledge, no such action or proceeding is pending therein;
(c) if I should thereafter learn that the same or similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or quasi-judicial
agency, I undertake to report such fact within five (5) days therefrom to the court or agency wherein
the original pleading and sworn certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this _____________ at

_____________, Philippines.

AFFIANT

SUBSCRIBED AND SWORN to before me, this _____________, by _____________

who exhibited to me (his/her) Community Tax Certificate No. _____________ issued at
_____________, Philippines on _____________.

NOTARY PUBLIC

Doc. No. ______;

Page No. ______;
Book No. ______;
Series of ______;

CERTIFICATION OF NON-FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES)

Province of ____________________) S.S.
City/Municipality of _____________)
x-----------------------x

I, _____________, of legal age, Filipino, (single / married / widow), and a resident of

_____________, Philippines, after being sworn in accordance with law, hereby depose and
certify that:

(a) I have not theretofore commenced any other action or proceeding or filed any claim
involving the same issues or matter in any court, tribunal, or quasi-judicial agency and, to the best of
my knowledge, no such action or proceeding is pending therein; (c) if I should thereafter learn that
the same or similar action or proceeding has been filed or is pending before the Supreme Court, the
Court of Appeals, or any other tribunal or quasi-judicial agency, I undertake to report such fact
within five (5) days therefrom to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this _____________ at

_____________, Philippines.

AFFIANT
 SUBSCRIBED AND SWORN to before me, this _____________, by _____________
who exhibited to me (his/her) Community Tax Certificate No. _____________ issued at
_____________, Philippines on _____________.

NOTARY PUBLIC

Doc. No. ______;

Page No. ______;
Book No. ______;
Series of ______;