Republic of the Philippines

Regional Trial Court

Branch 20
Catarman, Northern Samar

AAA DELA CRUZ,

Plaintiff,
Civil Case No. 000001
-versus- For: Sum of Money

BBB DE ASIS,
Defendant.
x-----------------------x

COMPLAINT

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

1. Plaintiff is a Filipino, of legal age, and resident of Brgy. Dalakit, Catarman;

defendant is also a Filipino, of legal age and resident of Brgy. Narra, Catarman, where he
may served with summons and other processes.

2. Sometime in March 2018 and over a period of six (6) months, defendant
borrowed certain amounts from the plaintiff. Defendant promised to pay these amounts
on installment basis monthly. These amounts now total Seven Hundred Thousand Pesos
(700,000.00).

3. Despite the repeated demands, both oral and written, defendant failed or has
refused to pay any amount to plaintiff as no installment payment has even made. A copy
each of plaintiff’s two (2) demand letters is attached as ANNEX A and B.

4. Resort to the Barangay Conciliation process proved fruitless as defendant failed

to appear, despite notice on him to appear. Thus, a Certification to File Action, a copy of
which is attached as ANNEX C, was issued by the Barangay Chairman.

5. Defendant’s obligation is due and demandable and plaintiff is entitled to the

payment of the entire amount of Seven Hundred Thousand Pesos (700,000.00).

6. By reason of defendant’s unreasonable failure or refusal to pay his due and

demandable obligation, plaintiff was forced to engage the services of counsel to vindicate
his rights thereby committing himself to pay legal expenses amounting to Fifty Thousand
Pesos (50,000.00).

PRAYER

WHEREFORE, plaintiff respectfully prays for judgment in his favor through a

Decision directing defendant to pay him SEVEN HUNDRED THOUSAND PESOS
(700,000.00), with legal interest, as ACTUAL DAMAGES and FIFTY THOUSAND
PESOS (50,000.00) as Attorney’s Fees.
Such other reliefs and remedies under the premises are likewise prayed for.

Catarman, Northern Samar, this 22nd day of October 2020.

(Sgd.) RENZIL BALICUDCUD

Counsel of the Plaintiff
PTR No. xxxx
IBP No. xxxx
Roll No. xxxx
ABC Building, Zone-1, UEP
Catarman, Northern Samar