REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 100
QUEZON CITY

BECKY N. POE,
Plaintiff,
Civil Case No. 567977
FOR: COLLECTION FOR A
SUM OF MONEY WITH
DAMAGES
- versus -

MA. MERCEDES GO,

Defendant
x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court,

hereby respectfully avers:

1. That plaintiff is of legal age, Filipino, married, and a resident of 4 th

Avenue, Don Sebastian Village, Quezon City, Philippines while the
defendant is also of legal age, married, Filipino and a resident of Brgy.
Bagong Toro, Quezon City, Philippines where summons and court processes
may be served;

2. That on February 10, 2018, the defendant borrowed from the

plaintiff a sum of money amounting to One Million Five Hundred Thousand
Pesos (P1,500,000.00) with an agreed interest of four percent (4%) per
month as evidenced by a promissory note herein attached as Annex “A” and
form an integral part of this complaint;

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

the defendant has become due and demandable on February 10, 2019;

4. That despite plaintiff's repeated demands, both written and verbal,

defendant failed, neglected and refused to fulfill obligations without just and
valid grounds to the continued damage and prejudice of plaintiff, as
evidenced by Annex “B” – Demand Letters;

5. That the plaintiff in order to enforce her rights and interests, has
sought the services of a legal counsel with attorney’s fees amounting to
Eighty Five Thousand Pesos (P85,000.00) and an appearance fee of Five
Thousand Pesos ( P5,000.00) per hearing as evidenced by Annex “C” –
Contract for Legal Services;

6. That the plaintiff has paid for litigation expenses amounting to

Twenty Thousand Pesos (P20,000.00) as evidenced by Annex “D” – Official
Receipt;

7. That the plaintiff has suffered moral damages at the sum discretion
of the Honorable Court;

WHEREFORE, premises considered, it is hereby respectfully prayed

before the Honorable Court to render decision in favor of the plaintiff and
order the defendant to pay the following:

a. the sum of One Million Five Hundred Thousand Pesos

(P1,500,000.00) plus interest at the rate of four percent (4%) per
month as stipulated in the promissory note;

b. attorney’s fees amounting to Eighty Five Thousand Pesos

(P85,000.00) and an appearance fee of Five Thousand Pesos
(P5,000.00) per hearing;

c. litigation expenses amounting to Twenty Thousand Pesos

(P20,000.00).

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

Quezon City, April 30, 2019.

ATTY. STEPHANIE MANI

Counsel for Plaintiff
Mani Law Office, 45th Bldg., Quezon Ave, Quezon City
Roll of Attorney;s No. 63321
PTR NO. 654761, 01/06/14, Quezon City
IBP NO. 198456, 01/04/14, Quezon City
MCLE Comp. No. IV-0009986, 01/02/14

VERIFICATION AND CERTIFICATION

JURAT