Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 6
Baguio City

GEORGIA P. SANTOS, CIVIL CASE No. 335-2831-44

Plaintiff,

FOR: Foreclosure of Real Estate

- versus – Mortgage

ANTONIA A. BABAO,
Defendant.
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COMPLAINT

COMES NOW, plaintiff, GEORGIA P. SANTOS, by counsel,

and unto this Honorable Court, most respectfully avers THAT:

1. That on April 21, 2016, the defendant executed a

promissory in favor of the plaintiff, heretofore attached as
Annex A and made an integral part of this complaint, in terms
and conditions as follows:

“FOR VALUE RECEIVED, I promise to pay to the order of

Georgia Santos, the principal amount of PESOS:
THREE HUNDRED AND FIFTY (P 350 000 ), on or
before July 3, 2017. In addition to the foregoing, I
promise to pay monthly interest at the rate of Two
( 2 %) percent, starting from the month of August
2016 until this note is fully paid.”

2. That to secure the payment of the promissory note,

defendant executed on April 20, 2016 a Deed of Mortgage in
favor of the plaintiff over a parcel of land whose technical
description is as follows:

TRANSFER CERTIFICATE OF TITLE NO. 12345

“A parcel of land located in Loakan Road, Baguio City known

as Lot A-3, bounded on the north by Lot B, on the South by Lot
C, on the west by Lot D, and on the South by National Road,

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 with a total area of 200 square meters, registered in the name
of Antonia A. Babao.”

3. Copy of said Deed of Mortgage is attached hereto,

marked Annex B and made as an integral part of this complaint;

4. That said mortgage was registered with the Office of the

Register of Deeds of Baguio City on May 2, 2016;

5. That payment of the issued promissory note is long

overdue and defendant has failed to pay the same despite
repeated demands;

PRAYER

WHEREFORE, the above premises considered, it is

respectfully prayed of this Honorable Court after hearing on the
merits, that:

a. Judgment be issued in favor of plaintiff ordering her to

pay the principal sum of THREE HUNDRED THOUSAND
PESOS (Php 350 000) until fully paid.

b. The aforementioned parcel of land be sold at public

auction should the defendant fail to pay the sums set forth
in this complaint and apply the proceeds thereof in
accordance with the dispositions of law;

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

Baguio City, Philippines, 2nd of September, 2019.

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REPUBLIC OF THE PHILIPPINES}
DONE: IN THE CITY OF BAGUIO } S.S.
X ---------------------------------------------- X

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, GEORGIA P. SANTOS, of legal age, Filipino, widow a

resident of #43 1st Road, Quezon Hill, Baguio City, Philippines and
after having been duly sworn to in accordance with law, do hereby
depose and state:

1. That I am the plaintiff in the above-entitled complaint;

2. That I personally caused the preparation of the foregoing

complaint;

3. That I have read and understood the contents of the

foregoing complaint and the allegations therein are true
and correct to the best of my own personal knowledge and
belief based on authentic documents;

I FURTHER CERTIFY THAT:

4. I did not therefore commence any action or any claim

involving the same issues in any court, tribunal or quasi-
judicial agency and to the best of my knowledge, no such
other action or claim is pending therein;

5. In the event that there is such other similar action or

proceeding or if I should hereafter learn that such similar
action or proceeding has been filed or is pending before
the Supreme Court, Court of Appeals and any court, or
any other tribunal or agency, I will promptly inform the
Honorable Court of the fact and status of the same within
five (5) days from knowledge there from.

IN WITNESS WHEREOF, I have hereunto set my hand this 2nd

day of September 2019 in the City of Baguio, Philippines.

GEORGIA P. SANTOS
Affiant
Professional Driver’s License No. VV12899103
Issued on: March 21, 1993

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 Issued at: Baguio City
SUBSCRIBED AND SWORN to before me in the City of Baguio
nd
this 2 day of September 2019, by GEORGIA P. SANTOS, who has
satisfactorily proven her identity to me through her Professional
Driver’s License No. indicated below her name, that she is the same
person who personally signed the foregoing affidavit before me and
acknowledged that she executed the same.

Doc. No.____;
Page No.____;
Book No.____;
Series of 2019.