STATEMENT OF CLAIM

SMALL CLAIMS CASE

(CASE OF JUAN DELOS REYES V. PEDRO SANTOS)

RONALD ARVIN C. CUSI

PRACTICE COURT I
Republic of the Philippines )
City of Calapan ) SS.
Province of Oriental Mindoro )

COMPLAINT AFFIDAVIT
I, JUAN CLARO DELOS REYES, of legal age, married, and a
resident of No. 45, Libis, Bauan, Batangas, after having been duly
sworn on oath in accordance with law, hereby voluntarily depose and
say:

1. That on June 15, 2019, PEDRO SANTOS, of legal age,

married, and resident of Calicanto, Batangas City, borrowed the
amount of Two Hundred Thousand Pesos (P200,000.00) to be
used as additional capital for restaurant business in Calicanto,
Batangas City;

2. That as per our agreement, the said obligation shall be returned

after six (6) months, or in December 15, 2019, and said
agreement was put into writing;

3. That in good faith and trust, after signing the promissory note, I
handed over to him the amount of Two Hundred Thousand
Pesos (P200,000.00) in cash;

4. That on December 15, 2019, PEDRO SANTOS failed to pay his

obligation to the affiant in the amount of Two Hundred
Thousand Pesos (P200,000.00);

5. That the defendant’s failure to pay prompted the affiant to issue

a demand letter notifying the defendant that his obligation is
already due and demandable, and failure to pay the same
would constitute legal ramifications against him;

6. That despite repeated verbal and written demands, the

defendant refused to pay the said obligation;

7. That I am executing this complaint affidavit for the purpose of

filing a collection suit against PEDRO SANTOS.

______________________
JUAN DELOS REYES
Affiant
 SUBSCRIBED AND SWORN to before me this 15th day of
February 2020 by affiant Juan Delos Reyes who personally appeared
before me and signed this document in my presence and presented
to me as competent proof of his identity his Philippine Regulation
Commission I.D. Card No. D1-0027194 with validity until November
3, 2022. I hereby certify that I have ascertained the identity of the
affiant through competent identification document.

_____________________
Atty. Robin D. Dimacuha
Attorney’s Roll No. 78854
IBP Lifetime No. 10000234
MCLE Compliance No.
857564
Nov. 3, 2018
 January 15, 2020

PEDRO SANTOS
Sitio Zone 15, Calicanto,
Batangas City 4200

DEMAND LETTER
Mr. Santos,

This is with respect to your loan acquired on June 15, 2019 in the
amount of Two Hundred Thousand Pesos (P200,000.00). It is with
deepest regret to remind you that the same is already due and
demandable.

As per our agreement reflected on the Promissory Note dated June

15, 2019, you are supposed to pay the full amount of the loan last
December 15, 2019. However, despite my repeated demand, you
failed and still fail to pay the amount of Two Hundred Thousand
Pesos (P200,000.00).

Moreover, may this serve as final demand and failure to comply with
the same, I will bring this matter to the proper court of law.

I am hoping for your compliance.

Best Regards,

JUAN DELOS REYES

Received on January 16, 2020 by:

PEDRO SANTOS
 PROMISSORY NOTE
I, PEDRO SANTOS, of legal age, married, and a resident of
Calicanto, Batangas hereby promises to pay JUAN DELOS REYES,
the amount of Two Hundred Thousand Pesos (P200,000.00), value of
the actual loan I obtained from him on or before DECEMBER 15,
2019.

Bauan, Batangas City.

June 15, 2019.

PEDRO SANTOS