asefereerfdsfdsdfdfdsfdsfdsfdsdsdRepublic of the Philippines

4th Judicial Region

Municipal trial court in Cities
Branch 2
Lucena City

MANNY MANINGIL, Civil Case No. 20-123456

Plaintiff FOR: SUM OF MONEY

- versus -

AYAW MAGBAYAD,
Defendant

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

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court,

hereby respectfully alleges:

1. That plaintiff MANNY MANINGIL is of legal age, Filipino, married,

and a resident of Unit 1, ELS Building, Granja St., Barangay 3,
Lucena City, Philippines where he may be served with summons and
processes of the court.

2. That defendant AYAW MAGBAYAD is also of legal age, married,

Filipino and a resident of 123 Quezon Avenue, Barangay 1, Lucena
City, Philippines where he may likewise be served with summons and
processes of the court.

3. That on January 1, 2020, the defendant borrowed from the plaintiff

the amount of One Hundred Thousand Pesos (Php 100,000.00) in cash
as evidenced by a promissory note herein attached as Annex “A” and
form an integral part of this complaint.

4. That as shown in the attached promissory note, the indebtedness of the

defendant has become due and demandable on January 8, 2020 which
he likewise promised to pay.
5. That despite plaintiff's written and oral repeated demands defendant
failed and continuously fail to fulfill his obligation without just and
valid reason to the continued damage and prejudice of plaintiff, as
evidenced by reminder letter of plaintiff hereto attached as Annex
“B”

6. That by reason in its efforts to collect, plaintiff was constrained to

seek the assistance of a counsel wherein the defendant was sent a
notice of final demand hereto attached as Annex “C” which was duly
sent and received by defendant through registered mail.

7. That up to this date from where the obligation fell due and
demandable the amount of Php 100,000.00 remains unpaid.

8. That due to the wrongful act committed by the defendant, the latter
should be held to pay plaintiff the principal amount of Php 100,000.00
plus legal interests of 12% per annum from January 8, 2020 until full
payment obligation is realized;

9. That by reason of the defendants willful and malicious refusal to

satisfy his obligation, plaintiff was constrained to engage the services
of a counsel in filing this case and paid the amount of Php 30,000.00
as attorney’s fee plus an appearance fee of Php 3,000.00 per hearing
and expects other litigation expenses in the amount of Php 20,000.00

10.That in order to warn others from emulating the same malevolent acts
done by the defendant an award of exemplary damages is proper in
the amount of Php 20,000.00

PRAYER

WHEREFORE, premises considered, after due which and hearing that a

decision be rendered:

a. For the defendant to pay the amount of P 100,000.00 plus legal

interest of 12% per annum from January 8, 2020 until fully paid

b. Php 30,000.00 as attorneys fees and Php 20,000.00 as litigation

expense.

c. Php 20,0000.00 for exemplary damages, and

d. Such other just and equitable reliefs under the premises.

__________________________, Lucena City

Respectfully submitted:

CHINA N. COVID
Counsel for the Plaintiff
nd
2 Floor, Unit 1 ESB Building, Barcelona St.,
Barangay 5, Lucena City
PTR No. 055555 1-3-20 Lucena City
IBP No. 99998 1-3-20 Lucena City
Attorneys Roll No. 8888
MCLE Compliance No. V-00000
Issued on August 28, 2019