Republic of the Philippines

11TH JUDICIAL REGION

Regional Trial Court
Branch 8
Davao City

DODONG S. TUKIB, Civil Case No. _____________

Plaintiff FOR: COLLECTION FOR A SUM OF
MONEY WITH DAMAGES
- versus -

MARVIN M. MERCEDEZ,
Defendant
x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court, hereby
respectfully avers:

1. That plaintiff is of legal age, Filipino, married, and a resident of Tubigon

Village, Panacan, Davao City, Philippines while the defendant is also of legal age,
married, Filipino and a resident of Brgy. Panacan, Davao City, Philippines where
summons and court processes may be served;

2. That on February 14, 2018, the defendant borrowed from the plaintiff a sum
of money amounting to Three Hundred Fifty Thousand Pesos (PhP 350,000.00) as
evidenced by a promissory note herein attached as Annex “A” and form an integral
part of this complaint;

3. That as shown in the attached promissory note, the indebtedness of the

defendant has become due and demandable on February 14, 2019;

WHEREFORE, premises considered, it is hereby respectfully prayed before

the Honorable Court to render decision in favor of the plaintiff and order the
defendant to pay the following:

a. the sum of Three Hundred Fifty Thousand Pesos (PhP 350,000.00)

b. litigation expenses amounting to Twenty Thousand Pesos (PhP 20,000.00).

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

Davao City, October 4, 2019.

ATTY. SANDY L. EDRALIN

Notary Public
Until December 31, 2022
N. A. No. 31-NC-12-R
Attorney’s Roll No. 96969
IBP No. 201233 01.02.2015 Davao City
PTR No. 1234567 01.02.2015 Davao City
MCLE Compliance No. XI-0000100; 08.04.2015