Republic of the Philippines

4TH JUDICIAL REGION

Regional Trial Court
Branch _____
Batangas City

SPOUSES PEDRO AND

MARIA DELA CRUZ, Civil Case No.123
_____________
Plaintiff FOR: COLLECTION FOR A
SUM OF MONEY WITH
DAMAGES
- versus -

BONG DE GUZMAN ,
Defendant
x -----------------------x

COMPLAINT

PLAINTIFFS, through the undersigned counsel unto this Honorable

Court, hereby respectfully alleges:

1. That plaintiffs are of legal age, Filipino, married, and a resident of

Batangas City, Batangas, Philippines while the defendant is also of legal
age, married, Filipino and a resident of Bacoor City, Cavite Philippines
where summons and court processes may be served;

2. That on January 15, 2019, the defendant borrowed from the

plaintiff a sum of money amounting to Three Hundred Twenty Thousand
Pesos (Php 320,000.00) with an agreed interest of five percent (5%) per
month as evidenced by a promissory note herein attached as Annex “A” and
form an integral part of this complaint;

3. That as shown in the attached promissory note, the indebtedness of

the defendant has become due and demandable on January 15, 2020;

4. That the one year period had lapsed and despite plaintiff's repeated
demands, both written and verbal, defendant failed, neglected and refused to
fulfill obligations without just and valid grounds to the continued damage
and prejudice of plaintiff, as evidenced by Annex “B” – Demand Letters;

5. That due to unjust refusal of the defendant to comply with the

demands, plaintiff was compelled to file instant action engaging the services
of a legal counsel, with attorney’s fees amounting to Fifty Thousand Pesos
(PhP 50,000.00) and an appearance fee of Three Thousand Pesos (PhP
3,000.00) per hearing as evidenced by Annex “C” – Contract for Legal
Services;
6. That the plaintiff has paid for litigation expenses amounting to Ten
Thousand Pesos (PhP 10,000.00) as evidenced by Annex “D” – Official
Receipt;

7. That the plaintiff has suffered moral damages at the sum discretion
of the Honorable Court;

WHEREFORE, plaintiffs respectfully prayed before the Honorable

Court to render decision in favor of the plaintiff and order the defendant to
pay the following:

a. the sum of Three Hundred Twenty Thousand Pesos (PhP

320,000.00) plus interest at the rate of five percent (5%) per month
as stipulated in the promissory note;

b. moral damages, exemplary damages at the sum discretion of the

court;

c. attorney’s fees amounting to FiftyThousand Pesos (PhP

50,000.00) and an appearance fee of Two Thousand Pesos (PhP
3,000.00) per hearing

d. litigation expenses amounting to Ten Thousand Pesos (PhP

10,000.00).

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

Batangas City, March 5, 2021.

JOMERY ANN M. NAVARRO

Counsel for the Plaintiff
XXX Law Office, Sta. Clara, Batangas City, Philippines
Roll of Attorneys No. 96321
PTR NO. 123456, 03/06/18, Batangas City
IBP NO. 123456, 03/04/18, Batangas City
MCLE Comp. No. IV-123456, 03/02/18
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF BATANGAS ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

We, PEDRO and MARIA DELA CRUZ, of legal age, Filipino,

married, and a residents of Batangas City, Batangas, Philippines, after being
sworn in accordance with law, hereby depose and say:

(1) That we are the Plaintiff in the above-entitled case;

(2) That we have caused the preparation of the above Complaint and
we have read the same and understood the contents thereof;

(3) That the allegations contained therein are true and correct of our
own personal knowledge and based on authentic records.

(4) That we further certify that: we have not theretofore commenced

any other action or proceeding or filed any claim involving the same issues or
matter in any court, tribunal, or quasi-judicial agency and, to the best of our
knowledge, no such action or proceeding is pending therein; if we should
thereafter learn that the same or similar action or proceeding has been filed or
is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, we undertake to report such fact within five
(5) days therefrom to the court or agency wherein the original pleading and
sworn certification contemplated herein have been filed.

IN WITNESS WHEREOF, We have hereunto set our hand this 5th

day of March 2021 at Batangas City, Philippines.

PEDRO DELA CRUZ MARIA DELA CRUZ

Affiant Affiant
TIN 1234-5678; Batangas City TIN 91011-1213; Batangas
City
 SUBSCRIBED AND SWORN to before me, this 5th day of March
2021 affiant exhibiting to me his Tax Identification Card as shown above
below his name as competent evidence of his identity.

JOMERY ANN M. NAVARRO

Counsel for the Plaintiff
XXX Law Office, Sta. Clara, Batangas City, Philippines
Roll of Attorneys No. 96321
PTR NO. 123456, 03/06/18, Batangas City
IBP NO. 123456, 03/04/18, Batangas City
MCLE Comp. No. IV-123456, 03/02/18

Doc. No. 1;
Page No. 2;
Book No. 1;
Series of 2021;