Republic of the Philippines

Supreme Court of the Philippines

Fourth Judicial Region
MUNICIPAL TRIAL COURT IN CITIES
BRANCH ____
Batangas City

JUAN DE LA CRUZ, CIVIL CASE NO.

Plaintiff, _____________________

Versus for

PEDRO SANTOS, COLLECTION OF SUM

Defendant. OF MONEY.
x-----------------------------------------x
COMPLAINT

COMES NOW, plaintiff JUAN DE LA CRUZ, by himself, unto

this Honorable Court, most respectfully avers:

1. That Juan de la Cruz (who will be referred to as the “Plaintiff”) is

of legal age, married, Filipino, with residence at C. Tirona St.,
Batangas City where he may be served with notices and other
processes by the Honorable Court;

2. That Pedro Santos (who will be referred to as the “Defendant”) is

of legal age, Filipino, single, with residence at 123 Brgy. Alalum, San
Pascual, Batangas, where he may be served with notices and other
processes by the Honorable Court;

3. That the Plaintiff is the sole proprietor of Juan Poultry Supply with
business address at C. Tirona St., Batangas City;

4. That the Defendant is one of the customers of the Plaintiff;

5. That during the years 2020-2021, the Defendant made the

following purchases from the Plaintiff:

Date                        Sales Invoice No.                          Amount

Oct.  2, 2020                   12301                                 P 50,000.00

Nov. 6, 2020                   12311                                   100,000.00
Dec. 5, 2020                   12315                                   100,000.00
Jan. 5, 2021                   12325                                   150,000.00
Feb. 9, 2021                   12335                                      50,000.00
Mar. 3, 2021                   12350                                      80,000.00

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                            Total (inclusive of interest)            P 530,000.00

6. That the Plaintiff has a policy that purchases on credit will be

subject to 5% interest and shall be payable within ten (10) days from
the date of the invoice which is acknowledged by the Defendant, a
copy of the policy showing the signature of the Defendant is hereto
attached as Annex “A”;

7. That on October 13, 2021, the Plaintiff reviewed his records and
found that the above-stated accounts have not yet been settled by
the Defendant, a copy of the records is hereto attached as Annex “B”;

8. That the Plaintiff was constrained to hire the services of Atty. Laika
A. Hernandez in order to prepare and send a demand letter against
the Defendant;

9. That on October 13, 2021, a formal demand letter was prepared

and personally received by the Defendant, a copy of the demand
letter showing that it was personally received by the Defendant is
hereto attached as Annex “C”;

10. That since the receipt of the demand letter, several personal
demands against the Defendant were made by the credit collector of
the Plaintiff but to no avail;

11. That it has been more than 10 days since the Defendant received
the demand letter and still he refuses to comply with the demands of
the Plaintiff;

12. That in view thereof, the Plaintiff has filed the instant Complaint in
order to collect from the Defendant the total outstanding balance
under the latter’s account.

PRAYER

WHEREFORE, it is respectfully prayed by the Plaintiff that after

due notice and hearing, he be awarded the following:

1. FIVE HUNDRED THIRTY THOUSAND PESOS

(Php530,000.00) to be paid by the Defendant in accordance to
his total outstanding balance from the Plaintiff;

2. LEGAL INTEREST from the time of finality of the Court’s

judgment until the full settlement by the Defendant;

3. ATTORNEY’S FEES in the amount of ONE HUNDRED

THOUSAND PESOS (Php100,000.00); and

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 4. LITIGATION EXPENSES according to the official receipts to
be presented by the Plaintiff.

Other reliefs and remedies deemed just and equitable under

the foregoing premises are likewise prayed for.

Batangas City, October 26, 2021

JUAN DE LA CRUZ
Plaintiff

By:
Laika A. Hernandez
1401052
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