REPUBLIC OF THE PHILIPPINES

Supreme Court
IN THE MUNICIPAL TRIAL COURT OF PALIMBANG
Province of Sultan Kudarat

SABENA AGLUSOLOS
Plaintiff, CIVIL CASE NO. ____________

-versus- -for-

CELSO BAYBAY COLLECTION OF SUM OF MONEY

Defendant,
x---------------------x

COMPLAINT
PLAINTIFF, by her assistant/representative unto this
Honorable Court most respectfully states THAT:

1. Plaintiff is Filipino, of legal age and a resident of

Brgy. Kanipaan, Palimbang, Sultan Kudarat while
Defendant is also Filipino, of legal age, married to
Norma Baybay and resident of San Roque, Palimbang,
Sultan Kudarat. They may be served with summons and
other processes of this Honorable Court at their
specified address;

2. On July 25, 2004, Defendant husband CELSO BAYBAY

borrowed from the Plaintiff the amount of FIFTY
THOUSAND PESOS (P50,000.00) in cash with a collateral
of his gasoline place located at Brgy. San Roque and
hauler truck as well as its agreed monthly interest in
consonance with the promissory note executed by the
said Defendant until this credit including the
interest shall have been fully paid. Photocopy of his
promissory note and joint affidavit of witnesses to
its execution are hereto attached as Annex “A and “B”
respectively;
3. However, despite verbal and written demands made by
the Plaintiff, Defendant has never paid the said
obligations and continued to be refused payment up to
the present. Photocopy of formal demand letter is
hereto attached as Annex “C”;
4. In truth and in fact, Plaintiff referred this concern
already to the Office of the Brgy. Captain of San
Roque, Palimbang, Sultan Kudarat, but no positive
resolution was ever made since Defendant disappeared
for more than a year. Photocopy of endorsement letter
from Brgy. Captain Charlito M. Balor and extract
report thereof from police blotter of Municipal Police
Station, Palimbang, Sultan Kudarat, are attached
hereto as Annexes “D” and “E” respectively;
WHEREFORE, premises considered, it is most respectfully
prayed that judgment be rendered ordering the Defendant to
pay Plaintiff the amount of FIFTY THOUSAND PESOS (P50,000.00)
in cash including the agreed monthly interest thereof
reckoned from the month Defendant executed his promissory
note until fully paid.
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 Other reliefs are likewise prayed for.

Palimbang, Sultan Kudarat. July 24, 2006.

SABENA AGLUSOLOS
Plaintiff

Assisted by;

PI RICHZEL BALADJAY ALUCILJA

Chief of Police
Palimbang Police Station
Palimbang, Sultan Kudarat

VERIFICATION &
CERTIFICATION

I, SABENA AGLUSOLOS, of legal age, and resident of Kanipaan,

Palimbang Sultan Kudarat, after having been duly sworn to in
accordance with law, do hereby depose and state THAT:

1. I am the Plaintiff in the instant case;

2. I cause the preparation and filing of the aforesaid

complaint before this Honorable Court;

3. I have read all the allegations therein and the same are
true and correct of my own knowledge on the basis of the
records at hand and that the annexes to the complaint are
true an correct copies of the original thereof;

4. I have not commenced any other action or proceeding

involving the same issues in the Supreme Court, the Court
of Appeals or different divisions thereof, inferior courts
or any other tribunal or agency and that to the best of our
knowledge, no such action or proceeding is pending in the
Supreme Court, Court of Appeals or different divisions
thereof, inferior courts or any other tribunal or agency;

IN WITNESS WHEREOF, I have hereunto set my hand this 24 th day

July 2006 at Palimbang, Sultan Kudarat.

SABENA AGLUSOLOS
Affiant
CTC NO. _______________
ISSUED ON ____________
AT _____________________

SUBSCRIBED and SWORN TO before me this 24th day of July 2006

at Palimbang, Sultan Kudarat. I HEREBY CERTIFY THAT I HAVE
PERSONALLY EXAMINED THE AFFIANT AND I AM SATISFIED THAT SHE
SUBMITTED VOLUNTARILY AND UNDERSTOOD THE SAME.

PI RICHZEL BALADJAY ALUCILJA

Chief of Police
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 Palimbang Police Station
Palimbang, Sultan Kudarat