REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 1
Manila

JUAN DELA CRUZ,

Plaintiff,
Civil Case No. 0001
For: Sum of Money
-versus-

PINA UTANG,
Defendant.
x-----------------------------------x

COMPLAINT

COMES NOW, the plaintiff through the undersigned counsel and to this Honorable Court,
respectfully alleges that:

1. The plaintiff Juan Dela Cruz is of legal age, single and a resident of 20 San Miguel St.,
Quiapo, Manila, and defendant Pina Utang is of legal age, single and a resident of 10 San
Miguel St., Quiapo, Manila;

First Cause of Action

2. On March 3, 2012, defendant obtained a loan from the plaintiff in the amount of FIFTY
THOUSAND PESOS (Php 50,000.00) for which he executed and delivered to plaintiff a
promisory note, a copy of which is hereto attached as “Annex A”, and made part of this
complaint, to wit:
(copy of the Promissory Note)
3. Despite the lapse of the period for the payment of the amount stated in said note, defendant
has not paid the same, or any part thereof or interest thereon;

Second Cause of Action

4. Plaintiff hereby incorporates the allegations of paragraph 1;

5. On October 03, 2012 defendant again obtained a loan from the plaintiff in the amount of ONE
HUNDRED THOUSAND PESES (Php 100,000.00) for which he executed and delivered to
the plaintiff a promissory note, a copy of which is hereto attached as “Annex B”, and made
part of this complaint, to wit;
(copy of the Promissory Note)
6. Despite the lapse of the period for the payment of the amount stated in said note, defendant
has not aid the same, or any part thereof or interest thereon;

WHEREFORE, it is respectfully prayed that judgment be rendered in favor of plaintiff and against
defendant for the sum of ONE HUNDRED FIFTY THOUSAND PESOS (Php 150,000.00) with interest at
the rate of six per centum (6%) per annum on each of the aforesaid notes, until paid; interest at the legal
rate on the interest due from the time of the filing of the complaint and attorney’s fees plus costs.
Such other reliefs as may be just and equitable under the premises are likewise prayed for.

City of Manila, Philippines, March 3, 2015.

ATTY. JUANICO FRANCISCCO

Counsel for Defendant
Unit 1, X Building, Recto, Manila
IBP No. 123456; 01/10/10 – Manila
PTR No. 1234567; 01/10/10 – Manila
Roll No. 12345; 5/05/05
MCLE No. I – 001234; 9/09/09
MCLE No. II – 115678; 9/09/09

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING