- versus -

AYAW MAGBAYAD,
Defendant

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

2. 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;

3. 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

4. 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