REPUBLIC OF THE PHILIPPINES

SECOND JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH_____
BAYOMBONG, NUEVA VIZCAYA

MACK MACK C. SANTILLAN

Plaintiff CIVIL CASE NO.__________

-versus-

COLLECTION OF SUM OF MONEY WITH

ARNOLD C. ALUMPIHIT III DAMAGES
Respondent

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

COMPLAINT

COMES NOW the Plaintiff, by the undersigned counsel, and unto the Honorable
Court, respectfully avers that:

1. PLAINTIFF is of legal age, single, Filipino and a resident of Villaverde Nueva Vizcaya,
where he may be serve with court processes;

2. RESPONDENT is likewise of legal age, single, Filipino and a resident of Kayapa,

Nueva Vizcaya, where he may be serve with court processes;

3. That on July 8, 2018, Plaintiff lend to the respondent the amount of two hundred
thousand pesos (P200,000.00) which was secured by a promissory note dated July
8, 2018 where the respondent promise to pay the plaintiff of the said amount on
November 12, 2018. Attached herewith is the promissory note dated July 8, 2018
as annex “A”;

4. That on September 30, 2018, the respondent once again made a request to the
plaintiff to lend him another sum of money in the amount of three hundred
thousand pesos (P300,000.000) again evidence by a promissory note dated
September 30, 2018. The aforesaid promissory note is hereby attached as annex
“B”;

5. That the maturity date of both promissory note is dated November 12, 2018;

6. That on November 12, 2018, the plaintiff handed the promissory note to the
respondent and demanded the payment of the full amount of five hundred
thousand pesos (P500,000.00) covered by the two promissory notes, but the

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 respondent requested to the plaintiff to give him ample time to settle his
obligation;

7. After a month the plaintiff again demanded from the respondent the payment of
its obligation but the respondent did not accede to the request of the plaintiff;

8. The on February 24, 2019 the plaintiff gave a demand letter (which is hereto
attached as annex “C”) to the respondent and ask the latter for the payment of its
obligations in the amount of five hundred thousand pesos (P500,000.00) within 30
days from the receipt of such demand letter, but the respondent did not comply
with it.

PRAYER

WHEREFORE it is most respectfully prayed of this honorable court that the

respondent be enjoin to pay the plaintiff of the full amount allege herein including legal
interest incurring at the time of the last demand until full payment of the said amount.
Likewise the plaintiff prayed that the respondent be enjoin to pay damages and
attorney’s fees for the litigation of the suit.

Bayombong, Nueva Vizcaya, September 11, 2019

JOHN CARLO TOLENTINO

Counsel for the Plaintiff

REPUBLIC OF THE PHILIPPINES}}

PROVINCE OF NUEVA VIZCAYA}}
MUNICIPALITY OF BAYOMBONG}}
X-----------------------------------------------X

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I MACK MACK C. SANTILLAN, of legal age, single, Filipino citizen and a resident of
Villaverde Nueva Vizcaya, after having been duly sworn in accordance with law, do hereby
depose and state that:
1. I am the plaintiff in the above-stated case ;
2. I have caused the preparation of the foregoing complaint;
3. I have read and understood the allegations therein contained and the same
are true and correct of my own personal knowledge and based on authentic
records;
4. I have not commenced any other action or proceeding involving the same
issues in the Supreme Court, the Court of Appeals, or other tribunal or agency;

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 5. To the best of my knowledge and belief, no such action or proceeding has been
filed or is pending before the Supreme Court, the Court of Appeals or other
tribunal or agencies;
6. That I should thereafter learn that a similar action or proceeding has been filed
or is pending before the Supreme Court, the Court of Appeals or any other
tribunal or agency , I undertake to report that fact within 5 days therefrom to
this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 11th day of September
2019 in Bayombong, Nueva Vizcaya.

MACK MACK C. SANTILLAN

Affiant
CEI: Passport No. E45564334

SUBSCRIBED AND SWORN TO before me this 11th day of September 2019 in

Bayombong, Nueva Vizcaya. Affiant exhibited to me his competent evidence of identity
as indicated below his name.

ATTY. JOHN CARLO R. TOLENTINO

NOTARY PUBLIC – NUEVA VIZCAYA
Not. Com. 01-02-2019
PTR No. 0001-2019
IBP OR No. 002002002 – 2019
Roll of Atty: 999990909
MCEL Com. No.:VI- 02002002
Bayombong, Nueva Vizcaya

CERTIFICATION

I HEREBY CERTIFY that I personally examined the affiant and I am satisfied that he
voluntarily executed and understood his declaration on the place and date above written.

ATTY. JOHN CARLO R. TOLENTINO

COPY FURNISH (By Registered Mail)

ARNOLD C. ALUMPIHIT III

Kayapa, Nueva Vizcaya

EXPLANATION

The service is made through registered mail because of lack of personnel and the
distance of the place makes personal service improbable.

ATTY. JOHN CARLO R. TOLENTINO

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