REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BACOLOD CITY, BRANCH IX

NENA ROSE Z. BUGRONG

Plaintiff
 

          – versus –                                    CIVIL CASE NO. 12345566

FOR: Collection of a Sum of Money

ROSHAN LANES TAGALIBOD

Defendant
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COMPLAINT

PLAINTIFF, thru the undersigned counsel, unto this Honorable Court

respectfully alleges:

1. The Plantiff is of legal age, Filipino, single and with residence at

#11 Kabukiran Street, Brgy. San Birhen, Bacolod City;

2. That the defendant ROSHAN LANES TAGALIBOD is likewise of legal

age, Filipino, single and with a residence at Blk 5, lot 5, Bangga Cegasco,
Purok Pahanocoy, Brgy. Sum-ag, Bacolod City, where she could be served
with summons and other processes of the court;

3. That on June 21, 2013, the defendant obtained a loan from the
plaintiff in the sum of Fifty Thousand Pesos and Fifty Centavos (P50,000.50)
to be fully paid on its due date which is on June 21, 2014 as evidenced by a
promissory note dated June 21, 2013, a photocopy of which is hereto
attached as Annex “A”;

4. That defendant was able to pay only the amount of P1,000.50

from the principal amount despite the lapse of the period to pay the loan,
defendant failed to pay her the total obligation thereby entitling the
plaintiff to be paid of the unpaid principal in addition to the agreed 30% per
annuity by way of interest and 30% per annum by way of penalty,

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photocopy of statement of account is hereto attached as Annex “B” and
made an integral part hereof;

5. That said loan now long overdue despite of repeated demands and
she failed and refused to pay the same as evidenced by the Demand Letters
send by the Plaintiff, photocopy of which is hereto attached as Annex “C”
and made an integral part hereof;

6. The repeated demands were made for the defendant to pay her
obligations but she failed to pay.

WHEREFORE, Plaintiff respectfully prays for judgment in its favor

through a decision directing the defendant:

a. To pay Plaintiff the sum of Forty Seven Thousand Five Hundred

Pesos (P49,000.00 with interest at 30% and 30% as penalty from June 21,
2014 until the full amount is paid;

b. Attorney’s Fees at 10% of the principal amount;

c. the cost of the suit

Other just and equitable reliefs are also prayed for.

Bacolod City, Negros Occidental, February 25, 2015

ATTY. CARLO FRANCES E. CABALLERO

Counsel for the plaintiff
NOBC Bldg., Gatuslao St., Bacolod City
Attorney’s Roll No. 098532
IBP No. 24525-01/03/15-Bacolod
PTR No. 53532- 01/03/15-Bacolod
MCLE Compliance No. IV-0012345 – November 17, 2014

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 VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, NENA ROSE Z. BUGRONG, of legal age, after having been duly sworn in
accordance with law, depose and state that:

1. I am a plaintiff in the foregoing Complaint for Sum of Money;

2. I caused the preparation of the Complaint, which I have fully read and
understand;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the

same issues in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

5. To the best of my knowledge and belief, no such action or proceeding is

pending in the Supreme Court, the Court of Appeals, or any other
tribunal or agency;

6. If 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 five
(5) days therefrom to this Honorable Court.

                                                                                         NENA ROSE Z.BUGRONG

                                         Affiant

                 SUBSCRIBED AND SWORN to before me this 25th day of February

2015 at Bacolod City, affiant exhibiting to me his Community Tax Certificate
No. 12345677 issued on January 3, 2015 at Bacolod City.
 

ATTY. CARLO FRANCES E. CABALLERO

NOBC Bldg., Gatuslao St., Bacolod City
Attorney’s Roll No. 098532
IBP No. 24525-01/03/15-Bacolod
PTR No. 53532- 01/03/15-Bacolod
MCLE Compliance No. IV-0012345 – November 17, 2014
Doc. No. 22
Page No. 32
Book No. 01
Series of 2015