REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL REGION

REGIONAL TRIAL COURT
CITY OF MAKATI, METRO MANILA

MAANN GO,
Plaintiff.

-versus- Civil Case No. 123456

For: Collection of Sum of
Money
MITCH SANTOS,
Defendant.
x-------------------------x

COMPLAINT
PLAINTIFF, through counsel, most respectfully states:
1. That plaintiff, MAANN GO, is of legal age, single, Filipino, with a
residential address at Barangay Forbes, Makati City, whereas the
defendant is likewise a Filipino, of legal age, single, and residing at
Barangay Dasmarinas, Caloocan City, where she can be furnished with
summons, pleadings, orders, and order notices issued by the Honorable
Court.

2. On November 15, 2021, the defendant sent a message to the plaintiff to

ask the plaintiff if the defendant could borrow Fifteen Million Pesos
(P15,000,000.00). The plaintiff, being a good friend, agreed to lend the
defendant the money. Then, on November 20, 2022, the plaintiff and
the defendant met in Dusit Thani Hotel in Makati to sign the loan
agreement. Under the loan agreement, the loan is due and demandable
on January 30, 2022.

3. The loan becomes due and demandable on January 30, 2022; hence, the
plaintiff went to the defendant’s house in Caloocan City to collect the
amount due. However, the defendant stated that she cannot pay that
day.
 4. The defendant and the plaintiff come to an agreement that the defendant
will personally pay the plaintiff the amount due and demandable
including the interest of five percent (5%) per annum. However, the
defendant never come to the plaintiff’s condominium in Makati City as
agreed by them to pay the amount due and demandable.

5. Hence, on February 27, 2022, the counsel of the plaintiff personally

sent a Notice of Dishonor to the defendant in her residence in Caloocan
City, and the defendant, on the other hand, personally received the
same. The defendant continues to refuse to pay the amount, even after
the second Notice of Dishonor with a Demand to Pay on March 10,
2022.

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is most respectfully

prayed of this Honorable Court that, after due hearing, judgment be rendered
against the defendant ordering the latter to pay the plaintiff as follows:

1. The amount of Fifteen Million Pesos (P15,000,000.00) representing the

amount of loan to the defendant;

2. The amount corresponding to the interest of five percent (5%) per

annum.

3. Attorney’s fees.

4. Cost of the suit.

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

The city of Makati, 21st of April 2022.

Atty. BELLE PEREZ

Counsel for the Plaintiff
Ayala Ave. cor. Makati Ave, Makati City
Roll No. 3252
IBP No. 7890123 issued at City of Makati on Jan. 15, 2022
MCLE Compliance No. 5576352
REPUBLIC OF THE PHILIPPINE)

CITY OF MAKATI ) S.S.

CERTIFICATION OF NON-FORUM SHOPPING

I, MAANN GO, am of legal age, single, Filipino, with a residential address
at Barangay Forbes, Makati City, after having been sworn in accordance with
the law, hereby depose and state:

1. That I have not commenced any action or filed any claim involving the
same issues in the Supreme Court, the Court of Appeals, the Regional
Trial Court, and other Court, tribunal, or quasi-judicial agency;

2. To my best knowledge, no such other action or claim is pending in the

Supreme Court, the Court of Appeals, the Regional Trial Court, and
other Court, tribunal, or quasi-judicial agency;

3. If I should learn that the same or similar action or claim has been filed
or is pending in the Supreme Court, the Court of Appeals, the Regional
Trial Court, and other Court, tribunal, or quasi-judicial agency, I shall
report that fact within five (5) calendar days to the court wherein my
aforesaid complaint or initiatory pleading has been filed.

VERIFICATION

1. I have initiated and prepared the current petition. I have read and
understand the contents thereof, and the facts stated in the petition are
true and correct to my knowledge and based on authentic records;

2. The pleading is not foiled to harass, cause unnecessary delay, or

increase the cost of litigation;

3. The factual allegations therein have evidentiary support or, if identified,

will likewise have evidentiary support after a reasonable opportunity of
discovery.

4. Any consequence because of the content of herein petition shall be dealt

with by the counsel and his/her law firm and such monetary punishment
shall not be passed to the client.
 MAANN GO
Affiant

SUBSCRIBED AND SWORN to before me this 21st day of May 2022

at City of Makati, Philippines. Affiant exhibited to me her Passport issued in
DFA Manila with No. PH1322-1242-141.

Atty. Isabelle P. Caspillo

Notary Public for City of Makati
Commission Serial No. 123456
Until December 31, 2022
Office Address:
Roll of Attorney No. 7890-123-456
PTR No. 7890/City of Makati / 01-15-22
IBP No. 56789 /01-15-22/ Makati City

Doc. No. 1
Page No. 1
Book No. 1
Series of 2022