Asefereerfdsfdsdfdfdsfdsfdsfdsdsdv Republic of the Philippines

4th Judicial Region

Municipal trial court in Cities
Branch 2
Lucena City

1. vMANINGIL, Civil Case No. 20-123456

h summons and dsvd and formscdsvvcxvd 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
he likewise promised to pay.

3. 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”

4. sd should be held to pay plaintiff the principal amount of

Pf100,000.00 plus legal interests of 12% per annum from January 8,
2020 until full payment obligation is realized;

5. 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

6. 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. f

Respectfully submitted: