Professional Documents
Culture Documents
Plaintiff,
Defendant.
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COMPLAINT
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A Parcel of Land (Lot _ Blk __ of Consolidation-Subdivision plan
(LRC) PCS-______, being a portion of the consolidation of Lots
______ and ______ (LRC) PSD-______, Lot __, PSD-______,
Lot __, PSD-________, LRC Rec. Nos. Nos. N-_____, _____,
_____, N-_____, N-_____, and_____; situated in the Brgy. San
Donisio, City of Manila, National Capital Region, Is. of Luzon.
Bounded on NE., point __ to __ by Road Lot ___, on the NW.,
point __ to __ by Road Lot ___, on the SE., point __ to __ by
Road Lot ___, and on the SW., point __ to __ by Road Lot ___;
Beginning at a point marked on the plan being N_Deg. __E from
BLLM no. __, CAD-__, Manila Cadastre; thence S_Deg._W to
point 2; thence S_Deg._W to point 3; thence N_Deg._W to point
4; thence N_Deg._E to point 5; thence S_Deg._E to point of be-
ginning, Containing an area of ONE THOUSAND FIVE HUN-
DRED (1,500) square meters more or less."
5. The mortgage was registered with the Registry of Deeds of the City
of Manila on July 10, 2018;
(Attached as Annex “C” is the demand letter sent by the plaintiff to the
defendant; and, Annex “C-1” is the demand letter personally received by
the defendant bearing his signature.)
9. Defendant has also agreed in the mortgage contract that should the
plaintiff foreclose the mortgage, the latter is entitled to receive the further
sum of 20% of the total amount due as attorney’s fees, expenses and costs;
and,
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10. There are no other persons having or claiming an interest on the
mortgaged property.
1. Ordering Pedro Cruz to pay unto the Honorable Court within the
reglementary period of ninety (90) days the sum of ONE MILLION PE-
SOS (P1,000,000.00), together with the stipulated interest of 6% per an-
num from and after one (1) year, plus the additional sum of 20% of the
total amount due as attorney’s fees, expenses and cost;
3. Ordering Pedro Cruz to pay Juan Santos the amount of ONE HUN-
DRED THOUSAND PESOS (P100,000.00) as moral damages and ONE
HUNDRED THOUSAND PESOS (P100,000.00) as exemplary damages;
Such other reliefs as may be deemed just and equitable under are like-
wise prayed for.
(signed)
Atty. A
Counsel for the Plaintiff
Address : 678 Taft Avenue, Manila
Tel. No. (02) 85331655
Email: atty.a@gmail.com
IBP Lifetime No. _______________
PTR No. ______________________
Roll No. ______________________
MCLE Exemption No. ___________
VERIFICATION AND
CERTIFICATION OF NON-FORUM SHOPPING
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REPUBLIC OF THE PHILIPPINES)
CITY OF MANILA ) S. S.
I, Juan Santos, of legal age, Filipino citizen, single, and resident of #123
Mithi St., Sampaloc, Manila, after having been duly sworn to in accordance
with law do hereby depose and say that:
2. I have caused the preparation of the foregoing Complaint and have read
the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
(signed)
Mr. Juan Santos
Affiant
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_____________________ issued at ____________________________ on
____________________ as competent proof of his identity.
(signed)
Atty. B
Notary Public
until December 31, 2019
Address: 23 St., Malate, Manila
_____________________________
_____________________________
Tel. No. _______________________
Email: atty.b@gmail.com
IBP Lifetime No. _______________
PTR No. ______________________
Roll No. ______________________
MCLE Exemption No. ___________
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