REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 1
Manila City

JUAN DELA CRUZ,

Plaintiff,

SCA No. 12345

For: Foreclosure of Real
-versus- Estate Mortgage

PEDRO SANTOS,
Defendant.
x-----------------------------------------x

COMPLAINT

Plaintiff Juan Dela Cruz, through the undersigned counsel, respectfully states that:

1. Plaintiff is of legal age, single, and a resident of 1 Recto Ave., Manila, while defendant
Pedro Santos is of legal age, single, and a resident or 11 Recto Ave., Manila.
2. On February 20, 2016, defendant borrowed Php 500,000 from plaintiff payable within
one year from said date, with 6% interest per annum, to secure oayment of such loan,
he executed on the same date a Real Estate Mortgage on his located in Manila City
covered by TCT No. 123456 of the Registry of Deeds of Manila, more particularly
described as follows:

(Technical Description of Property)

3. Copy of said real estate mortgage is attached hereto and made integral part hereof as
Annex “A”
4. Said Real Estate Mortgage was registered with the Registry of Deeds of Manila on
February 28, 2016.
5. Said Real Estate Mortgage is the first mortgage constituted on said and no oter person
is claiming any other interest thereon.
6. One-year period has expired, without defendant paying the principal amount and interest
thereon. Accordingly, plaintiff demand of defendant to pay his overdue obligations,
despite such demands, defendant continually refuses to pay the same.

PRAYER

WHEREFORE, plaintiff prays for judgment as follows:

a. Ordering defendant to pay plaintiff to pay Php 500,000 with 6% interest per
annum from February 28, 2016.
b. Upon failure of defendant to pay in full his obligations within the period set by
law, to issue a decree of foreclosure for the sale at public auction of the above-
described parcel of land and for the disposition of the proceeds thereof in
accordance with law.
Other reliefs as may be just and equitable are likewise prayed for.

City of Manila, March 3, 2016.

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

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