REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Seventh Judicial Region
Branch 99
Oton, Iloilo

Thomas Shelby, CIVIL CASE NO. 12-23-45-69

Plaintiff, For: Collection of Sum of Money
-versus-

Alfred Solomons,
Defendant.
x------------------------------------------x

COMPLAINT

COMES NOW, PLAINTIFF, through the undersigned counsel and unto this
Honorable Court, most respectfully states that:

PERSONAL CIRCUMSTANCES

1. Plaintiff Thomas Shelby, of legal age, Filipino, married with address at

Brgy Balabago, Jaro, Iloilo City, Philippines where it may be served with
summons and other processes of the Honorable Court.

2. Defendant Alfred Solomons is of legal age, Single, Filipino and a resident

of Brgy. San Antonio, Oton, Iloilo, Philippines where she may be served
with orders, notices and other legal processes of this Honorable Court;

CAUSE OF ACTION

3. On January 10, 2019, defendant Solomons leased from plaintiff a house

and lot at Brgy. Indorohan, Badiangan, Iloilo for one year up to January
10, 2020.
4. Defendant has only paid January 2019 to August 2019
5. Defendant has not paid said rent from September 2019 onwards.

DOCUMENTARY EVIDENCE

6. Plaintiff will present the following documentary evidence:

a. Contract of Lease (Exhibit “A”) executed by Thomas Shelby,
plaintiff,
 b. Promissory note of payment by Defendant (Exhibit “B”) dated
September 2019 executed by defendant Solomons in favor of the
plaintiff; and
c. Demand letters (Exhibit C) written by undersigned counsel and
addressed to defendant.

PRAYER

WHEREFORE it is respectfully prayed that the defendant be ordered to pay

plaintiff the amount of Php 8,000.00 beginning September 2019 to January 2020.

Plaintiffs pray for such other and further relief as maybe deemed just and
equitable under the premises.
Oton, Iloilo. 19 December 2020.

ACOSTA LAW OFFICE

Counsel for the Plaintiff
Mambog Building
San Nicolas, Oton, Iloilo
By:

ATTY. DUNE ACOSTA

09143287921
Mambog Building
San Nicolas, Oton, Iloilo

Doc. No. 99
Page No. 999
Book No. 9999
Series of 2020
 REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
Seventh Judicial Region
Branch 99
Oton, Iloilo

THOMAS SHELBY, CIVIL CASE NO. 12-23-45-69 For:

Plaintiff, Collection of Sum of Money
-versus-

ALFRED SOLOMONS,
Defendant.
x------------------------------------------x

ANSWER

COMES NOW, DEFENDANTALFRED SOLOMONS, through the undersigned

counsel and unto this Honorable Court, most respectfully states that:

1. Defendant admits Pars. 1 to 3 of the Complaint;

2. Defendant denies Pars. 4 and 5 of the Complaint because he has paid

monthly rental without fail

3. Defendant has paid until expiry of said Contract which was up to January
2020.

4. Defendant has signed a second contract of lease executed by Plaintiff

WITNESSES AND SUMMARY OF THEIR TESTIMONIES

5. Defendant herself will testify that on September, 2020 he has personally

paid the said rental amount of Php 8,000.00 Pesos to Thomas Shelby,
plaintiff, and that he handed to him an official receipt acknowledging
the said payment
 DOCUMENTARY EVIDENCE

6. Defendant will present the acknowledgment receipt dated SEPTEMBER,

2020 and signed by THOMAS SHELBY, plaintiff.

PRAYER

WHEREFORE it is respectfully prayed that the complaint be dismissed for

lack of update of records of said payment

Defendant prays for such other and further relief as maybe deemed just
and equitable under the premises.
Oton, Iloilo. 19 December 2020.

ACOSTA LAW OFFICE

Counsel for the Plaintiff
Mambog Building
San Nicolas, Oton, Iloilo
By:

ATTY. DUNE ACOSTA

09143287921
Mambog Building
San Nicolas, Oton, Iloilo

Doc. No. 88
Page No. 998
Book No. 9999
Series of 2020
Doc. No. 99
Page No. 999
Book No. 9999
Series of 2020