Republic of the Philippines

8th JUDICIAL REGION

Regional Trial Court
Branch 8
Tacloban City

Civil Case No. _654321-1234__

JAMES C. BOYD, FOR: COLLECTION FOR A
Plaintiff SUM OF MONEY WITH
DAMAGES

- Versus –

PAOLO D. RAMA,
Respondent

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COMPLAINT

That the Plaintiff, through the undersigned counsel unto this Honorable Court, hereby
respectfully avers:

1. That she is of legal age, Filipino, Single, and a resident of Brgy. 1, real street,
Tacloban City 6500, Philippines, while the Respondent is also of legal age, Single,
Filipino and a resident of Brgy. 70, Marasbaras, Tacloban City 6500, Philippines,
where summons and court processes may be served;

2. That on January 1, 2022, the defendant borrowed from the plaintiff a sum of money
amounting to Two Million Pesos (PhP2,000,000.00), which was due on January 31st
of 2022, with an interest of 5% 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 31st, 2022;

4. That 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 the plaintiff in order to enforce his rights and interests, has sought the services of
a legal counsel with attorney’s fees amounting to One Hundred Thousand Pesos (PhP
100,000.00) and an appearance fee of Two Thousand Pesos (PhP 2,000.00) per
hearing as evidenced by Annex “C” – Contract for Legal Services;

6. That the plaintiff has paid for litigation expenses amounting to Twenty Thousand
Pesos (PhP 20,000.00) as evidenced by Annex “D” – Official Receipt;

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

Attached to this document are the following:

1. Annex “A” – Promissory Note
2. Annex “B” – Demand Letters
3. Annex “C” – Contract for Legal Services
4. Annex “D” – Official Receipt
5. Annex “E” – Judicial affidavit

WHEREFORE, premises considered, it is hereby 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 Two Million Pesos (PhP 2,000,000.00) plus interest at the rate of five
percent (5%) as stipulated in the promissory note;

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

c. attorney’s fees amounting to One Hundred Thousand Pesos (PhP 100,000.00) and an
appearance fee of Two Thousand Pesos (PhP 2,000.00) per hearing

d. Litigation expenses amounting to Twenty Thousand Pesos (PhP 20,000.00).

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

Tacloban City, February 28, 2022.

ATTY. JAYSON KRISTOPHER PABLO-CORONEL

Counsel for Petitioner
Coronel Law Office, Marasbaras, Tacloban City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/01/21, Tacloban City
IBP NO. 123456, 01/01/21, Tacloban City
MCLE Comp. No. IV-00054321, 01/01/21

Doc. no. ______

Page no. ______
Book no. ______
Series of 20__

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 ANNEX “A”

February 14, 2019

I, PAOLO D. RAMA agree and promise to pay JAMES C. BOYD the amount of Two Million Pesos
(PhP 2,000,000.00) on or before March 7, 2019

PAOLO D. RAMA

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 ANNEX “B”

Demand Letter

March 20, 2019

PAOLO D. RAMA
Tacloban City

Dear Mr. RAMA,

I would like to inform you, that despite numerous oral requests, your balance of sTwo million pesos
(PhP 2,000.000.00) is still unpaid.

Kindly settle your account with me within the week, to avoid further inconvenience.

Kind Regards,

JAMES C. BOYD

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 Final Demand Letter

April 30, 2019

PAOLO D. RAMA
Tacloban City

Dear Mr. Rama,

I regret to inform you that despite my previous letter your balance of Two millioin pesos (PhP
2,000.000.00) is still due and outstanding.

Unless you contact me within 48 hours to exact full payment, I will be forced to commence legal action
to enforce payment of your indebtedness, plus added expenses, consider this my FINAL DEMAND.

Regards,

JAMES C. BOYD

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 ANNEX “C”

May 15, 2019

Contract for Legal Services

This is to certify and acknowledge that Mr. James Boyd has come to our office, Coronel
Law Office, located at Marasbaras, Tacloban City, to seek legal counsel in filing a case for
recovery of a sum of money with damages against Mr. PAOLO D. RAMA, for and in behalf of a
loan obtained by Mr. Rama from Mr. Boyd, for the sum of Two Million Pesos (Php 2, 000,000.00).

This is also to confirm that Mr. Boyd, has paid for the initial legal acceptance fee to our office
and is formally recognized as a client of Coronel Law office.

Signed this day May 15th, 2019, at Coronel Law Office, Tacloban City.

ATTY. JAYSON KRISTOPHER PABLO-CORONEL

Counsel for Petitioner
Coronel Law Office, Marasbaras, Tacloban City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/01/21, Tacloban City
IBP NO. 123456, 01/01/21, Tacloban City
MCLE Comp. No. IV-00054321, 01/01/21

Doc. no. ______

Page no. ______
Book no. ______
Series of 20__

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 ANNEX “D”

City of Tacloban

May 15, 2019

Official Receipt

Received From: Coronel Law Office

PhP 2,000.00 for litigation expenses

Blakay Gripon

Cashier

ATTY. JAYSON KRISTOPHER PABLO-CORONEL

Counsel for Petitioner
C.A.R.D law office and accociates
De veyra bldg., Burgos street, Tacloban City
0917-987-6543
MCLE no.: 1234-5678
Roll of Atty's no.: 2024-1234
IBP no.: 1234-5678
PTR no.: 1234-5678

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 ANNEX “E”
Republic of the Philippines
8th JUDICIAL REGION
Regional Trial Court
Branch 8
Tacloban City

Civil Case No. _654321-1234__

JAMES C. BOYD, FOR: COLLECTION FOR A
Plaintiff SUM OF MONEY WITH
DAMAGES

- Versus –

PAOLO D. RAMA,
Defendant

x -----------------------x

x--------------------------------------------------x

JUDICIAL AFFIDAVIT OF JAMES BOYD

This Judicial Affidavit of JAMES BOYD, who is the plaintiff in this case, is executed
to serve as his direct testimony in the instant case. This Judicial Affidavit is being
offered to prove the following:

A.) All the allegations in the complaint including all annexes appended thereto
and which were already marked as exhibits in the case;

B.) All other related matters, facts and circumstances relevant and
material to this case. This Judicial Affidavit was taken at the office of
Atty. JAYSON CORONEL at 1MARASBARAS, Tacloban City, Leyte. The
questions were propounded by Atty. CORONEL in English language which the
witness fully understands and are numbered consecutively followed by an answer
of the witness.

Q1. Do you swear to tell the truth and nothing but the truth?
A1. I do.

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Q2. Are you aware that you can face criminal liability for false testimony
or perjury if you will not tell the truth?
A2. Yes, I am.
Q3. Please state your name, age, and address.
A3. I am JAMES BOYD, 34 years old and residing at MARASBARAS,Tacloban City
Q4. Do you know Mr. PAOLO RAMA?
A4. Yes.
Q5. How did you come to know Mr. RAMA?
A5. He is my friend and neighbor
Q6. How long have you and Mr. RAMA know each other?
A6. Almost 5 years
Q7. Did Mr. RAMA approach you for a loan?
A7. Yes
Q8. What kind of loan did he avail?
A8. It is a cash loan for TWO million pesos through a promissory note to serve as
collateral and evidence of the loan.
Q9. I am showing you this document, herein referred to as Annex “A”. Do you
know this document?
A9. Yes.
Q10. What is this document?
A10. It is a promissory note, Atty.
Q11. Who executed this promissory note?
A11. Mr. RAMA, Atty.
Q12. When was this promissory note executed by Ms. Perez?
A12. On February 14, 2019.
Q13. When does the promissory note become due and demandable?
A13. Three years after or on March 14, 2019
Q14. After the Promissory Note becomes due and demandable, what did you
do?
A14. I sent him a demand letter to pay the loan within a week from the receipt of
the demand.
Q15. I am presenting to you this document herein referred to as Annex “B”.
Do you know this document?
A15. Yes. That is the first demand letter which was duly received by Mr. RAMA.
Q16. How did you come to know this document?
A16. I was the one who issued it, atty..
Q17. Was there any payment made by Ms. RAMA in response to the demand?
A17. No. Mr. RAMA did not pay the loan.
Q18. I’m showing you this document herein referred to as Annex “C”. Do you
know about this document?
A18. Yes. That document is the final demand letter duly receive by Mr. RAMA.
Q19. How did you come to know this document?
A19. I was also the one who issued the same.
Q20. Was there any payment made?
A20. No, Atty.

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Q21. Did Mr. RAMA make any attempts to communicate to you regarding the
said loan.
A21. No.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th day of May
2019 at Tacloban City, Province of Leyte

JAMES BOYD
Affiant

SWORN ATTESTATION

The undersigned hereby attests that, as counsel of the witness, he

faithfully recorded the questions he asked and the corresponding answer of the
witness, and that he did not coached the witness answers to the questions
propounded.

ATTY. JAYSON KRISTOPHER PABLO-CORONEL

Counsel for Petitioner
Coronel Law Office, Marasbaras, Tacloban City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/01/21, Tacloban City
IBP NO. 123456, 01/01/21, Tacloban City
MCLE Comp. No. IV-00054321, 01/01/21

Doc. no. ______

Page no. ______
Book no. ______
Series of 20__

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