REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
MAKATI CITY
BRANCH 14

P1 Civil Case No. xxxxx

Plaintiff, FOR: COLLECTION FOR
SUM OF MONEY
-versus-
D1
Defendant.

x-----------------------------------------------x

COMPLAINT

Plaintiff, by counsel, states that:

1. P1 (Plaintiff), is of legal age, Filipino, single, and a resident of No. 123 Makati St. Makati
Village, Makati City.
2. D1 (Defendant), is of legal age, Filipino, single, and a resident of No.123 Tarlac St. Tarlac
Village, Tarlac City.
3. On 1 April 2018 for valuable consideration, defendant executed a Promissory Note, under
the terms and conditions specified therein, in the sum of Eight Hundred Thousand
(PhP800,000.00) Philippine Currency with an agreed interest rate of 12% per annum, both
principal amount and interest payable in lump sum on 31 March 2019. A copy of said
Promissory Note is here attached as Annex “A,” and made integral part hereof.
4. As shown in the attached promissory note, the indebtedness of the defendant has become
due and demandable on 31 March 2019.
5. Without any legal justification, defendant continuously refuses to pay the said amount
despite repeated oral and written demands. A final demand letter was sent and received
personally by defendant on 1 August 2019, or more than ten (10) days before the filing of
this complaint. A copy of the final demand is here attached as Annex “B.”
6. By reason of continued refusal of the defendant to settle his loan obligation, plaintiff has
been constrained to institute this instant case to protect its right and interest.

WHEREFORE, plaintiff prays that:

1. After due notice and hearing, the Honorable Court to render decision in favor of the plaintiff
and order the defendant to pay the sum of Eight Hundred Thousand (PhP800,000.00)
Philippine Currency plus the interest at the rate of 12% per annum as stipulated in the
promissory note;
2. Moral and actual damages be paid at the sum discretion of the Court including the
attorney’s fees and the litigation fees;
3. Other reliefs and remedies deemed just and equitable are likewise prayed for.

Makati City, 12 September 2019.

(Signed)
ATTY. XXX
No. 12345 Makati St. Makati Village, Makati City
Roll of Attorney No. 12345
IBP No. 12345/ xx-xx-2019 / Makati City
PTR No. 12345/ xx-xx-2019 / Makati City
MCLE No. 12345/ xx-xx-2019 / Makati City
Contact No. 12345
E-mail: xxx@gmail.com
 VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, P1, of legal age, Filipino, after having been sworn, in accordance with law, states that:

1. I am the Plaintiff in the above-captioned case;

2. I have read and understood the contents of the above Complaint, and the facts herein
alleged are true and correct of my knowledge and based on authentic records;
3. I further certify that I have not commenced any other action or proceeding or any claim,
or filed any claim involving the same issues raised in the above-captioned cases, in
this Honorable Supreme Court, in the Court of Appeals, nor the different Divisions
thereof, nor in any other court or tribunal or agency and, to the best of my knowledge,
no such action or proceeding is pending therein;
4. I hereby undertake to notify this Honorable Court of such fact within five (5) days from
receipt of such knowledge, should I come to learn that the same or a similar action or
claim has been filed or pending in the Supreme Court, Court of Appeals, the different
Divisions thereof, or any other court or tribunal or agency;
5. I am executing this sworn statement in compliance with Section 5, Rule 7 of the 1997
Rules of Court.

(Signed)
P1
Affiant

SUBSCRIBED and sworn to before me, this 13th day of September, 2019, in the City of
Makati by the affiant with Passport No. 12345, issued on 13 August 2018 at Manila City,
Philippines.

(Signed)
ATTY. YYY
NOTARY PUBLIC for Makati City
Commission Serial No. 12345
Until 31 December 2019
Roll of Attorney No. 12345
IBP No. 12345/ xx-xx-2019 / Makati City
PTR No. 12345/ xx-xx-2019 / Makati City
MCLE No. 12345/ xx-xx-2019 / Makati City
No. 123456 Makati St. Makati Village, Makati City
Contact No. 12345
E-mail: yyy@gmail.com

Doc. No. 12345;

Page No. 12345;
Book No. 12345;
Series of 2019.