REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

MUNICIPAL TRIAL COURT
BRANCH ____
ROSARIO, BATANGAS

GLORIA BACUNO,
Plaintiff,

-versus- Civil Case No: _______________

For: Collection for Sum of
Money

MARCELLA OCAMPO,
Defendants.
x-------------------------------------------------x

COMPLAINT

COMES NOW Plaintiff, Gloria Bacuno, through undersigned counsel

and unto this Honorable Court, most respectfully states that;

1. Plaintiff Gloria Bacuno is a Filipino of legal age, married and currently

residing at Barangay Mayuro, Rosario, Batangas;

2. Defendant Angelica De Leon is married, of legal age, Filipino, and

currently an occupant at B. Zuno St., Barangay E (Poblacion),
Rosario, Batangas, where she may be served with summons and other
processes of this Honorable Court;

3. Plaintiff, together with her husband, were former Overseas Filipino

Workers who were able to fund various businesses in Rosario,
Batangas upon their return. Defendant is a former employee in one of
their businesses who grew close to them because of the duration of
service she has rendered;
4. On August 15, 2019, defendant came to the office of plaintiff.
Defendant said that she is having a family problem because her
husband suddenly left their home without leaving any money for
them. She further said that she was in dire need of money as her
eldest child was required to be admitted at the hospital because of
pneumonia and she has been unemployed since her resignation from
the plaintiff’s company;

5. Plaintiff, on even date, lend her money with the amount of twenty-five
thousand pesos (P25,000). Defendant executed a promissory note and
indicated therein that she is supposed to pay plaintiff on October 1,
2019. Said promissory note executed by the defendant is hereby
attached and made as an integral part of this complaint as Annex “A”;

6. On September 16, 2019, defendant again met up with plaintiff and

told her that the hospital bills she is supposed to pay exceeded up to
ninety-five thousand pesos (P95,000). Plaintiff agreed and defendant
executed two promissory notes dividing the foregoing amount, now
forty-seven thousand five hundred pesos (P47,500) to be paid in two
different dates: on November 25, 2019 and on December 30, 2019.
These two (2) promissory notes are hereby attached and made as an
integral part of this complaint as Annex “B” and Annex “C”,
respectively;

7. On October 1, 2019, plaintiff came to visit defendant at the place

where the latter is staying. Defendant was surprised and mentioned
that she got lost counting off the dates and forgot that it was the due
date for her first debt. Plaintiff demanded from her the payment for
the first loan and mentioned that if she fails to pay, it will be harder
for her to fulfill the other obligations for they will pile up;

8. Defendant offered to have a partial payment but plaintiff declined and

said that the period for payment they have agreed upon was already
initiated by her (defendant). Such fact made the plaintiff assured that
 she will be able to pay on such date. Defendant plead for two-week
extension. Plaintiff agreed but told her that she should be paying in
full;

9. On October 15, 2019, plaintiff sent a demand letter to defendant and

repeatedly sent text messages to her as well reminding the latter of the
payment for the loan. All these efforts turned futile. Defendant failed
to pay her first obligation;

10. Plaintiff never stopped from sending her demand letters because she
was not able to personally go to the defendant anymore as she became
very busy with her office works. Plaintiff however managed to go to
defendant on the due dates indicated for the other two promissory
notes but her efforts were all futile. Defendant always hides from the
plaintiff and even changed her phone number;

11. From the foregoing facts, it is evident that defendant has failed to
comply her obligation indicated in the mentioned three (3) promissory
notes which she executed and signed herself.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court that judgment be rendered in favor of the plaintiff and
that after judgement;

a. The defendant shall pay the amount due based on her obligations as
indicated in the three (3) promissory notes in the amount of ONE
HUNDRED FIFTEEN THOUSAND (P115,000);
b. The defendant shall be ordered to pay P 30, 000 for the Attorney’s
Fees; and
c. Such other reliefs and remedies under the premises are likewise
prayed for.
January 27, 2020 at Rosario, Batangas, Philippines.
 ATTY. MARIA ACONTE
Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97:
Gualberto Ave. Poblacion A,
Rosario, Batangas
REPUBLIC OF THE PHILIPPINES)
MUNICIPALITY OF ROSARIO )S.S.
PROVINCE OF BATANGAS )

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING

I, Gloria Bacuno, of legal age, after having been duly sworn in

accordance with law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
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.

Gloria Bacuno
Affiant

SUBSCRIBED AND SWORN to before me this 27 th day of January,

2020 at Rosario, Batangas affiant exhibiting to me her Driver’s License with
No.DOJ-01-0087.
Doc. No. ; ATTY. MARIA ACONTE
Page No. ; Counsel for the Plaintiff
Book No. ; PTR No. 18909595:1-04-07:B.C.
Series of 20__. IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97:
Gualberto Ave. Poblacion A,
Rosario, Batangas