NARRATIVE OF FACTS

Sometime on September 14, 2018, Defendant LEILA D. SAMPO obtained from

and was granted a loan accommodation by the Plaintiff JONEL X. AFAM in the principal
amount of Thirty Thousand Pesos (P 30,000.00) due and demandable on December 14,
2018.

As of December 14, 2019, Defendant still has an Outstanding Balance to Plaintiff

amounting to Ten Thousand Pesos (P10,000.00), and has failed and neglected to pay,
without just and valid grounds, the said Outstanding Balance for the aforementioned
loan accommodation. 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.

During several dialogues between the Plaintiff and Defendant, held at the
Barangay Hall of Putik, Defendant continue to refuse to pay the amount due to Plaintiff
thus compelling the Plaintiff to raise the issue before the Office of the Lupong
Tagapamayapa of Barangay Putik. There being no amicable settlement arrived at, the
Office of the Lupong Tagapamayapa issued a Certificate to File Action against the
Defendant.

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 ten (10%)
percent of the total amount due from Defendant to Plaintiff.