Republic of the Philippines

[Region]
[COURT]
[City], [Branch No.]

[NAME]__________,
Plaintiff,
Civil Case No. ___________
- versus - For: Foreclosure of Real
Estate Mortgage

[NAME]__________,
Defendant.
x ----------------------------------- x

COMPLAINT

Plaintiff mortgagee, by counsel, respectfully states that:

1. The plaintiff mortgagee , ____________ [NAME], is of legal age, Filipino, [single /

married / widow], and a resident of ____________________, Philippines;

1. On _____________, the defendant mortgagor-debtor, ______________ [NAME] of

legal age, Filipino, [single / married / widow], and a resident of _____________,
Philippines, executed a Real Estate Mortgage in my favor mortgaging said property
described in the Real Estate Mortgage Contract hereto attached as Annex “A” and
forming an integral part hereof; to secure the payment of loan in the amount which is
shown in the promissory note executed by said Mortgagor-Debtor dated
_____________, a copy of which is hereto attached as Annex “B”

2. That to the best of my knowledge, the mortgaged property is subject to no prior

mortgage or any lien whatsoever and is now in the possession and full control of the
above-named defendant Mortgagor-Debtor;

3. That the defendant Mortgagor-Debtor defaulted in its obligation under the

aforementioned Real Estate Mortgage Contract and Promissory Note;

4. That under Rule 68 of the Rules of Court, the Mortgagee is entitled to foreclose
judicially the mortgaged property, which is more particularly described as follows:

[Technical Description of Property]

5. That by the terms and conditions of the Real Estate Mortgage Contract herein-above
referred to, the principal obligation of the Mortgagor which has become overdue as of
_____________ is in the amount of __________________________ (P___________),
excluding penalties, liquidated damages, past due interest, attorney’s fee representing
______% of the total obligation due, other charges and expenses of foreclosure.

WHEREFORE, plaintiff mortgagee respectfully prays that the Court render judgment
for the sum due and order that the same be paid to the court or to the judgment oblige within
the period prescribed by law and that in default of such payment the property be sold at public
auction to satisfy the judgment.

Other just and equitable reliefs are also prayed for.

 [CITY] ____________; [DATE] ____________________________.

[SIGNATURE]
[NAME] _____________
Counsel for Plaintiff
[ADDRESS] ______________________

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

I, [NAME] _____________________, of legal age, do hereby state that: I am the

plaintiff in the pleading/document entitled [PLEADING/DOCUMENT BEING VERIFIED]
___________________ and in such capacity, caused this Complaint to be prepared; I have
read its contents and affirm that they are true and correct to the best of my own personal
knowledge; I hereby certify that there is no other case commenced or pending before any
court involving the same parties and the same issue and that, should I learn of such a case, I
shall notify the court within five (5) days from my notice.

IN WITNESS WHEREOF, I have signed this instrument on [DATE]_____________.

[SIGNATURE]
[NAME] _________________

SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day

of [MONTH AND YEAR]_________________, affiant exhibiting before me his Government
Issued ID no. _______________ issued on [DATE}__________________ at [PLACE OF
ISSUANCE]_____________________.

[SIGNATURE]
[NAME]_______
Notary Public

Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________

Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.