REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

First Judicial Region
Branch 416B
Baguio City

PROF E. SSOR, Civil Case No. _____

Plaintiff, For: Collection of Sum of
Money with Prayer of writ
-versus- for the issuance of
Preliminary Attachment
DO C. TOR,
Defendant.

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COMPLAINT

PLAINTIFF, through counsel, most respectfully avers:

1. That plaintiff, PROF E. SSOR, is a Filipino citizen, of legal age,

single and a resident of #01 Unang St., First Village, Baguio City, at which
address the party herein may be served with summons and other court
processes

2. That defendant, DO C. TOR, is likewise a Filipino, of legal age,

single, and residing at #02 Pangalawang St., Second Village, Baguio City, at
which address the party herein may be served with summons and other court
processes;

3. That on January 1, 2017, defendant borrowed from plaintiff the

amount of FIVE MILLION PESOS (P5,000,000.00), which indebtedness is due
and payable on or before January 1, 2018, with an interest at the rate of 10%
per annum and 5% penalty for delay, in accordance with the written loan
agreement executed by the plaintiff and defendant on the said date.
Photostatic copy of said loan agreement is attached and marked as Annex “A”
and made as an integral part hereof;

4. That the defendant has failed and refused to pay the said
indebtedness on due date, with corresponding interest and penalty thereon to
the herein plaintiff, despite repeated requests and demands.
 5. That the plaintiff served several demand letters to the defendant.
Attached is the last demand letter executed on August 1, 2019 by the plaintiff
as Annex “B” and made as an integral part hereof;

6. That the defendant shall pay for the attorney’s fees and expenses
of litigation in the amount of P100,000.00 and a fee of P10,000 for every
appearance in court, and to pay the cost of this suit;

Allegations for the Issuance of for Preliminary Attachment

7. That Plaintiff has a valid and sufficient cause of action against the
herein defendant regarding the collection of sum of money which is already
due and demandable;

8. That Defendant has removed or disposed of or is about to remove

or dispose of her property, with intent to defraud her creditors thereby
rendering nugatory and ineffective whatever money judgment this honorable
court may render in the above entitled case;

9. That the defendant does not have sufficient security for the claim
sought for the plaintiff against him;

10. That the plaintiff is willing to put up a bond for the issuance of a
preliminary attachment in an amount to be fixed by the court;

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable Court

that, pending hearing of this case, a writ of preliminary attachment be issued
against the property of the defendant to serve as security for the satisfaction
of any judgment that may be recovered herein; and that after due hearing on
the principal cause of this action, judgment be rendered against the defendant
for the sum of the following:

1. Ordering defendant to pay plaintiff the amount of FIVE MILLION

PESOS (P5,000,000.00) plus interest thereon at the rate of 12% per annum
from January 1, 2017, and a 5% penalty for delay, until the same is fully paid;
and
 2. Ordering defendant to pay the attorney’s fees and expenses of
litigation in the amount of P100,000.00 and a fee of P10,000 for every
appearance in court, and to pay the cost of this suit.

Plaintiff likewise prays for such other and further relief or reliefs as this
Honorable Court may deem just and equitable under the premises.

Baguio City, Philippines, August 22, 2019.

KING ANTHONY M. MONTEREAL

Counsel for the Plaintiff
#1 Upper Session Rd., Baguio City
Roll No. 999999
IBP No. 09999999/June 13, 2018
Baguio-Benguet Chapter
PTR No. 8888888/June 06, 2019
MCLE Certificate of Compliance No. 1111111
REPUBLIC OF THE PHILIPPINES)
BAGUIO CITY. . . . . . . . . . . . . . . ) S.S

VERIFICATION AND CERTIFICATION

I, PROF E. SSOR, of legal age, single, Filipino and a resident of #01

Unang St., First Village, Baguio City, under oath depose and state that:

I am the Petitioner in the above captioned case; I have caused the

preparation of the same; I have read the allegations contained therein; and I
certify that they are all true and correct to the best of my own knowledge

I further certify under oath that I have not commenced any similar
action before the Supreme Court, Court of Appeals, or before any court,
tribunal or agency concerned; and should I learn of any similar cause of action
filed before any of the aforesaid bodies, I undertake to notify this Honorable
Court within five (5) days from notice.

In witness whereof, I have hereunto set my hand this 22nd day of August,
2019 at Baguio City.

PROF E. SSOR
Affiant

SUBSCRIBED AND SWORN TO before me this 22nd day of August, 2019 at

Baguio City, Philippines. Affiant exhibited to me his Nonprofessional Driver’s
License No. 099-09-000999 issued on January 1, 2018 in the City of Baguio.

STEVE JACK MA
Notary Public for and in the City of Baguio
Until December 31, 2019
Contact No. +63916 201 9144
Roll No. 111111
Doc. No. 01; TIN No. 111-111-111
Page No. 02; IBP No. 99999 – Baguio City – 02/02/2019
PTR No. 99999 -Baguio City – 08/08/2018
Book No. XX; MCLE Certificate of Compliance No. 0000001
Series of 2019. Upper Session Rd., Baguio City