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Assigned Case Bank of Luzon v. Reyes PDF
Assigned Case Bank of Luzon v. Reyes PDF
BANK OF LUZON
Plaintiff,
JOSE REYES
Customer No. XXXXXXXXXXXXX
Defendant
X-------------------------------X
COMPLAINT
PLAINTIFF, BANK OF LUZON (herein after referred
to as “BL”) by counsel to this Honorable Court
respectfully states that:
PRAYER
FE LAUREL
Counsel for the Plaintiff
5 Zamora St. Pasay City
IBP No. XXXXX-Pasay City-1/12/09
PTR No. XXXXXX-Pasay City-1/12/09
MCLE Compliance No. II-XXXXXX-08/26/08
Roll No. 33453
VERIFICATION AND CERTIFICATION
MEL VELEZ
Affiant
SUBSCRIBED AND SWORN to before me this ____ day of ____ 2009, at
_____________, affiant exhibiting to me her CTC No. 03861181 issued at Manila on March 6,
2009 and Passport No. UU670597, thus satisfactorily having proven her identity to me.
BANK OF LUZON
Plaintiff,
JOSE REYES
Customer No. xxxxxxxxxx
Defendant,
x---------------------------------------------------x
AFFIDAVIT
.
2 As Account Officer presently assigned with
the Collection/Legal Department of the corporation, I
handle the records and monitor payments of
delinquent cardholders, send demand letters to them,
and actively participate in the collection of the
obligations of the cardholders. I have also been
authorized to represent the corporation in court cases
involving collections as may be gleaned from by
Special Power of Attorney issued by the said
corporation, which is hereto attached as Exhibit “A”
and Corporate Secretary’s Certificate as Exhibit “A-1”.
.
3 In the course of the performance of my
duties, functions and responsibilities as Account
Officer of the corporation, I came to know that Jose
Reyes applied with the corporation for the issuance of
BL Card under Customer Number xxxx-xxxx, became
some of the delinquent accounts that I am handing
and monitoring.
.
5 On several occasions, the defendant
through the use of his BL card, purchased goods
and/or services on credit as shown by the
Ledgers/Monthly Statements of Account sent to her
which are hereto attached and made integral parts
hereof as follows:
.
7 As a consequence thereof, plaintiff
engaged the services of its external counsel, Atty. Fe
Laurel, for which the plaintiff agreed to pay 25% of the
total amount due as and by way of attorney’s fees for
the purpose of enforcing its claim against the
defendant.
.
8 Thus, the plaintiff through the above-
mentioned counsel, filed complaint against Jose
Reyes, and docketed as Civil Case No. xxxx which is
pending before Metropolitan Trial Court in Makati City,
Branch x.
MARIBEL
CRUZ
Affiant
SUBSCRIBED AND SWORN to before me in the
City of Makati this ____ day of ____ 2010, affiant
exhibited to me her Comm. Certificate No. 03861183
issued at Manila on March 4, 2009.
BANK OF LUZON
Plaintiff,
JOSE REYES
Customer No. XXXXXXXXXXXXXXXXX
Defendant
X-------------------------------X
JUDICIAL AFFIDAVIT
A: Yes, Ma’am.
A: Yes Ma’am,
MIKE
SANTOS
Affiant
ATTESTATION
ATTY. FE
LAUREL
BANK OF LUZON
Plaintiff,
JOSE REYES
Defendant
X-------------------------------X
ANSWER
PRAYER
ANTHONY CRUZ
Counsel for the Defendant/s
Roll of Attorney’s No. 57359
IBP No. 810801/01-09 10/RSM
MCLE Compliance number (N/A)
Compliance period up to April 2010 per
MCLE Governing Board No. 1, s. 2008
VERIFICATION
Copy Furnished:
FE LAUREL
Counsel for the Plaintiff
5 Zamora St., Pasay City
SERVICE EXPLANATION
TONY PEREZ
REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL REGION
BANK OF LUZON,
Plaintiff,
- versus -
Civil Case No. ____________
JOSE REYES,
Defendant.
x-------------------------------------------------x
JUDICIAL AFFIDAVIT
Witness:
JOSE REYES, of legal age, Filipino, and resident of Apple Village, Dasmarinas Cavite.
Examining Lawyer:
MARIA R. DELA CRUZ
th
6 floor Makati City Hall Building,
Poblacion, Makati City
Place of Examination:
Public Attorney’s Office, Makati District
th
6 floor Makati City Hall Building,
Poblacion, Makati City
JOSE REYES
Affiant
SUBSCRIBED AND SWORN TO before me this 19th day of February,2013 at the Public
Attorney’s Office in Makati City, Philippines. Affiant exhibiting to me his GSIS
Multipurpose ID No. 123-1234-1234-1
NOTARY PBLIC
ATTESTATION OF COUNSEL
th
I, MARIA DELA CRUZ, single, Filipino, of legal age with office address at 5 floor, new
Makati City Hall Building, JP Rizal St. Poblacion Makati City, after having been sworn to
in accordance with law, hereby attest that:
3. Neither 1 nor any other peron then present r assisting me coached the witness
regarding the latter’s answer.
SUBCRIBED th
AND SWORN to me this 12 day of February 2013 at Makati City,
Philippines. Affiant exhibited to me here IBP ID with Lifetime Membership NO. 12345
FAY ABRENICA
Copy Furnished:
Atty Fe Laurel