Asefereerfdsfdsdfdfdsfdsfdsfdsdsdv Republic of the Philippines

4th Judicial Region

Municipal trial court in Cities
Branch 2
Lucena City

1. vMANINGIL, City, Philippines where he may be served with

summons and dsvd and form an integral part of thdsis complaivnt.

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

defendant has become due and demandable on January 8, 2020 which
evidenced by reminder letter of plaintiff hereto attached as Annex
“B”

3. 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.

4. That up to this date from where the obligation fell due and;

That tby reason of the defendants willful and malicious refusal to satisfy
his obligation, plaintiff wah constrained to engage the services of a
counsel in filing this case and paid the amounuht of Php 30,000.00 as
attorney’s fee plus an appearance fee of Php 3,000.00 per hearing and
gtttolent acts done by the defendant an award of

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

tttt

Respectfully submitted:
 CHINA N. COVID
Counsel fottr the Plaintiff
nd
2 Floor, Unit 1 ESB Building, Barcelona St.,
Barangay 5, Lucena City
r No.tt 8888
MCLE Compliance No. V-00000
Issued on August 28, 20ttt19