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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT


_______ JUDICIAL REGION
________________________

AAA, CIVIL CASE NO. _______


Plaintiff,

-versus - -f o r-

BBB & CCC, COLLECTION OF


SUM OF MONEY
Defendant.
x-x-x-x-x-x-x-x-x-x-x-x-x-x-x-x-x-x

COMPLAINT

Plaintiff, AAA, by herself and unto this Honorable Court, most respectfully
alleges that:

THE PARTIES

1. Plaintiff, AAA, is of legal age, married, Filipino and a resident of


______________ where she may be served with copies of orders and other
processes of this Honorable Court;

2. Defendants Spouses BBB and CCC, are both of legal age, Filipinos and
with residence at Brgy. X where summons and other processes of the
Court may be served;
3. Plaintiff instituted this civil action for collection of sum of money against
the defendants in the amount of ONE HUNDRED THOUSAND
(P100,000) PESOS, exclusive of its legal interest;

CAUSE OF ACTION

4. On July 10, 2003, Plaintiff extended a loan to Defendant Spouses in the


amount of ONE HUNDRED THOUSAND (P100,000), a copy of the
Notarized Kasulatan ng Utangan is hereto attached as Annex “A” and
made an integral part hereof;

5. In accordance with the said Kasulatan ng Utangan, the loan granted by


the Plaintiff to the Defendant Spouses will be due and demandable on
_____________;

6. Defendant spouses failed to pay the Plaintiff the amount of ONE


HUNDRED THOUSAND (P100,000) on _____________;

7. Despite the oral and written demands made by Plaintiff to the Defendants,
the latter still failed to settle their obligation, a copy of the Demand Letter
in behalf of the Plaintiff to Defendant BBB and her daughter, DDD is
hereto attached as Annex “B” and made an integral part hereof;

8. When Defendant spouses still failed to settle their obligation despite the
repeated oral and written demands made by the Plaintiff to the Defendant
Spouses, the former brought the matter for possible conciliation/amicable
settlement before the Tanggapan ng Lupong Tagapamayapa of Barangay
_________________ where the Defendant spouses were residents;

9. The efforts of the Lupon Tagapamayapa of Barangay ______________


failed and a Certificate to file Action was issued to the Plaintiff on
__________________ 20__, a copy of the said Certification is hereto
attached as Annex “C” and made an integral part hereof;

10. Due to the repeated refusal of Defendant Spouses to pay their obligation,
Plaintiff was constrained to secure the services of a lawyer and to assist
her in the filing of this case.

PRAYER

WHEREFORE, it is most respectfully prayed of the Honorable Court


that after due hearing, judgment be rendered in favor of the plaintiff and
against the defendants ordering them to pay plaintiff the following:

1. The principal amount of ONE HUNDRED THOUSAND


(P100,000) PESOS plus legal interest until the amount is fully paid;

2. Attorney’s fees in the amount of FIFTY THOUSAND (P50,000)


PESOS;

3. Cost of suit.

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

Z City for Y, _________________.


AAA
Plaintiff
CERTIFICATION AND VERIFICATION

REPUBLIC OF THE PHILIPPINES )


IN THE CITY OF ____________ ) S.S.

I, AAA, of legal age, married, Filipino and a resident of _____________, after


having duly sworn to in accordance with law, hereby depose and state:

That I am the Plaintiff in the above-entitled Complaint and that I have caused
the preparation of the same;

That no other action or proceeding involving the same issues has been hereto
commenced in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;

That to the best of my knowledge, no such action or proceeding is pending in


the Supreme Court, the Court of Appeals, or any other tribunal of agency;

That if I should thereafter learn that a similar action or proceeding has been
filed or is pending in the Supreme Court, the Court of Appeals or any other tribunal
or agency, we undertake to report the fact within five (5) days therefrom to the
Honorable Court.

Z City for Y, _________________.

AAA
Plaintiff
SUBSCRIBED AND SWORN to before me this _____ day of ________,
20__ at ________________, Philippines, affiant exhibiting to me her
________________ID. No. ____________________ issued on _____________ at
_____________________.

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 20___.