REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region

Branch 153

Taguig

KIM CHI

Plaintiff

Civil Case No. 001

For Sum of Money

- versus -

ANO BAH

EWAN KHU

BAHA LANA

Defendants

X-----------------------------------x

COMPLAINT

Plaintiff, by undersigned counsel and to this Honorable Court, respectfully states:

1. The plaintiff Kim Chi is of legal age, single and a resident of Unit 23 C One
Serendra Condominium, Taguig City, and defendant Ano Bah is of legal age, single and
a resident of 119 Cambridge Circle, Forbes Park, Makati City;
 First Cause of Action

2. On January 20, 2021, plaintiff and defendant executed a contract that the
former will be investing the amount of THREE MILLION PESOS (Php 3,000,000.00) for
which the latter will use to purchase a thousand boxes of Nitrile gloves worth of the
same amount invested, a copy of which is hereto attached as “Annex A”,

3. The same amount will be returned to the herein plaintiff, together with its ONE
HUNDRED PERCENT (100%) profit or with an equivalent value of THREE MILLION
PESOS (Php 3,000,000.00), after THIRTY (30) DAYS or on February 19, 2021, by the
defendant.

4. And that, failure of the defendant to return the capital and its profit on the
agreed date, will entitle the herein plaintiff to FIVE PERCENT (5%) of interest every
month until the capital and profit agreed upon has been returned to the plaintiff.

5. On May 3, 2021, defendant issued a post-dated check in favor of the herein

plaintiff, in the amount of SIX MILLION PESOS (Php 6,000,000.00), duly signed by
Ewan Khu and Baha Lana, directors of Ano Bah Pharmaceutical Company, which is
owned by the defendant, a copy of which is hereto attached as “Annex B”.

6. On May 11, 2021, plaintiff deposited the check but on May 12, 2021, the said
check bounced, hence, plaintiff demanded the payment of SIX MILLION SIX HUNDRED
THOUSAND PESOS (Php 6,600,00.00) from the defendant, for the amount invested by
the herein plaintiff together with its profit and interest.

Second Cause of Action

7. Plaintiff hereby incorporates the allegations of paragraphs 6;

8. A demand letter was sent to the defendant's address on May 13, 2021 and
was received on the same date by the defendant’s secretary, a copy of which is hereto
attached as “Annex C”, and made part of this complaint.

9. Despite the lapse of the period for the payment of the amount stated in said
contract and demand letter, defendant has not paid the same, or any part thereof or
interest thereon;
 WHEREFORE, it is respectfully prayed that judgement is rendered on favor of
plaintiff and against defendant for the sum of SIX MILLION NINE HUNDRED
THOUSAND PESOS (Php 6,900,00.00), which includes profit of ONE HUNDRED
PERCENT (100%) and a monthly interest at the rate of FIVE PERCENT (5%) on each
of the aforesaid notes, from February 20, 2021 to May 20, 2021, until paid; legal and
attorney’s fees plus costs.

Plaintiff further prays for such other reliefs as may be just and equitable in the
premises.

City of Taguig, June 18, 2021.

(Sgd.) ATTY. DANIEL MANZANILLA

Counsel for Defendant

Unit 6, Building A, Tomas Morato, Quezon City

Roll No. 12345: 6/7/86

IBP No. 678901: 12/25/86 - Quezon City

PTR No. 2345678: 1/21/89 - Quezon City

MCLE No. I-90123: 9/23/88

MCLE No. II-45678: 9/23/88