REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 41, Quezon City

SPS. JULIETA BARRETA-ANDERSEN Civil Case No.12345

and GERRY ANDERSEN, For: Damages for Breach of
Plaintiffs, Contract
-versus-

ACE WEDDING AND EVENTS, INC.

as represented by JOSHUA GARCI
Defendant.
x------------------------------------------------x

COMPLAINT

Plaintiffs thru counsel, and unto this Honorable Court, respectfully manifest:

1. That plaintiffs spouses Julieta Barreta-Andersen and Gerry Andersen are both
Filipino, of legal age, married, and with residence at 1515 Mabuhay St., Quezon City;

2. That defendant Ace Wedding and Events, Inc. (ACE) is a domestic corporation
duly organized under Philippine law, engaged in the business of wedding services and facilities
as a wedding coordinator, planner or provider with principal office address at 12th Floor, 365,
Regency Building, Makati City represented by Mr. Joshua Garci;

3. That for cause of action against the defendant, it is hereby stated that the plaintiffs
are scheduled to have their wedding on October 15, 2021 and have desired to engage the
wedding services and facilities of the defendant for the entire wedding package of P5,000,000.00
which shall be paid 50% initial payment upon signing of the contract, 25% one (1) week before
the wedding and another 25% one (1) week after the wedding, as evidenced by the Wedding
Planner Contract herein attached as Annex “A” and form an integral part of this complaint;

4. That as shown in the attached contract, the defendant will provide for the gowns
and attires of the bridesmaids and the groomsmen, the maid of honor and the best man, and the
flower girls and ring and coin bearers. The defendant will likewise provide the church
decorations, photography, wedding invitations and wedding giveaways;

5. That while the initial transactions and coordination with Beabi Alonzito, the
bridesmaid and confidante of the couple-plaintiffs, and ACE went well, when Beabi Alonzito
had to go to abroad for an emergency, the couple-plaintiffs found it hard to communicate with
ACE as there were unreturned calls and messages;

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 6. That on June 15, 2021 at the 12th floor, 365 Regency Building, Makati City, the
plaintiffs signed the said contract, of which a receipt was issued by ACE to the plaintiffs attached
herein as Annex “B”;

7. That because of lack of coordination, days before the wedding, some of the
members of the entourage were not yet called for the fitting and the venue of the reception was
not yet paid by ACE. Two days before the wedding, some of the members of the entourage did
not yet receive their clothes, while on the wedding day, several mishaps happened. Some
bridesmaids and groomsmen complained of ill fitted clothes and some of the flower girls’ gowns
did not arrive. The photographer arrived late and the church was badly decorated with guests
observing that some of the decorations were recycled from another reception. Even during the
reception, the foods were served late leaving the guests hungry;

8. That because of this lack of coordination, the event became a disaster;

9. That the plaintiffs in order to enforce their rights and interests, have sought the
services of a legal counsel;

10. That the plaintiffs have suffered moral damages at the sum discretion of the
Honorable Court;

PRAYER

WHEREFORE, IN VIEW OF THE FOREGOING, plaintiffs through counsel pray

this Honorable Court, after due hearing, to adjudge defendant Ace Wedding and Events, Inc., as
represented by Joshua Garci, to pay the following:

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

b. 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

c. 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.

Quezon City, March 23, 2022.

ATTY. NAIM NOHAR A. SUBA, CPA

Counsel for Petitioner
Lim Ket Kai Kai Law Office, Quezon City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Quezon City
IBP NO. 123456, 01/04/14, Quezon City

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 REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 41, Quezon City

SPS. JULIETA BARRETTA ANDERSEN Civil Case No.12345

and GERRY ANDERSEN, For: Damages for Breach of
Plaintiffs, Contract
-versus-

ACE WEDDING AND EVENTS, INC.,

as represented by JOSHUA GARCI
Defendant.
X--------------------------------------------------x

COMPLIANCE

1. Julieta Baretta-Andersen To testify that she is the plaintiff/

complainant in the instant case and
that she caused the filing of the same
and to identify documents pertinent
thereto. A copy of her Joint Judicial
Affidavit with her husband,
Gerry Andersen, is appended
as Annex “C”.

2. Gerry Andersen To testify that he is the plaintiff/

complainant in the instant case and
that she caused the filing of the same
and to identify documents pertinent
thereto. A copy of his Joint Judicial
Affidavit with his wife,
Julieta Baretta-Andersen,
is appended as Annex “D”.

Respectfully submitted.

Quezon City, March 29, 2022.

ATTY. NAIM NOHAR A. SUBA, CPA

Lim Ket Kai Kai Law Office, Quezon City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Quezon City
IBP NO. 123456, 01/04/14, Quezon City

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REPUBLIC OF THE PHILIPPINES)
QUEZON CITY ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

We, SPOUSES JULIETA BARRETA-ANDERSEN and GERRY ANDERSEN, of

legal age, Filipino, married, and both with residence at 1515 Mabuhay St., Quezon City,
Philippines, after being sworn in accordance with law, hereby depose and say:

(1) That we are the Plaintiffs in the above-entitled case;

(2) That we have caused the preparation of the above Complaint and we have read the
same and understood the contents thereof;

(3) That the allegations contained therein are true and correct of our own personal
knowledge and based on authentic records;

(4) That we further certify that: we have not theretofore commenced any other action or
proceeding or filed any claim involving the same issues or matter in any court, tribunal, or quasi-
judicial agency and, to the best of our knowledge, no such action or proceeding is pending
therein; if we should thereafter learn that the same or similar action or proceeding has been filed
or is pending before the Supreme Court, the Court of Appeals, or any other tribunal or quasi-
judicial agency, we undertake to report such fact within five (5) days therefrom to the court or
agency wherein the original pleading and sworn certification contemplated herein have been
filed.

IN WITNESS WHEREOF, we have hereunto set our hands this 23rd day of March 2022
at Quezon City, Philippines.

JULIA BARRETTA-ANDERSEN
Affiant
PRC ID No. 11111
Issued on March 14, 2017

GERRY ANDERSEN
Affiant
National ID No. 222222
Issued on January 01, 2022

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 SUBSCRIBED AND SWORN to before me, this 23rd day of March 2022, the affiants
exhibiting to me their PRC and National Identification Cards as shown above below their name
as competent evidence of their identity.

ATTY. NAIM NOHAR A. SUBA, CPA

Counsel for Petitioner
Lim Ket Kai Kai Law Office, Quezon City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Quezon City
IBP NO. 123456, 01/04/14, Quezon City

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2022.

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Republic of the Philippines}
National Capital Region}S.S.
CITY OF QUEZON

CERTIFICATION

I, NAIM NOHAR A. SUBA, having been duly sworn to in accordance with law hereby
depose and state that:

1. I am the counsel for Plaintiffs/Complainants Julieta Baretta-Andersen and Gerry

Andersen in the above-entitled case, and have read the pleadings and documents thereto.

2. To the best of my knowledge, information and belief, formed after an inquiry reasonable
under the circumstances certify that:

a. Sps.Andersen have read and understood the foregoing complaint.

b. The pleading or document is not being presented for any improper purpose, such as to
harass, cause unnecessary delay, or needlessly increase the cost of litigation.
c. The claims, defenses, and other legal contentions are warranted by existing law or
jurisprudence, or by non-frivolous argument for extending, modifying, or reversing
existing jurisprudence.
d. The factual contentions have evidentiary support or, if specifically identified, will
likely have evidentiary support after availing of the modes of discovery.
e. Denials of factual contentions are warranted by evidence or, if specifically so
identified, based on belief or lack of information.

3. Sps. Andersen have not heretofore commenced any other action or filed any claim
involving the same issues in any court, tribunal or quasi-judicial agency; and to the best
of my knowledge, no such other action or claim is pending therein; and that if there is
such pending action or claim, a complete statement of the present status thereof, and I
should thereafter learn that the same or similar actions or claim has been filed or is
pending, I shall report that fact within five (5) calendar days therefrom to the Honorable
Court.

March 29, 2022, Quezon City.

ATTY. NAIM NOHAR A. SUBA, CPA

Affiant

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 SUBSCRIBED AND SWORN to before me, this 29th day of March 2022 at Quezon
City, Philippines, Affiant personally appeared with his IBP ID No. 12345 known to me and to
me known to be the same person who executed the foregoing certification and verification.

ATTY. NAIM NOHAR A. SUBA, CPA

Lim Ket Kai Kai Law Office, Quezon City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Quezon City
IBP NO. 123456, 01/04/14, Quezon City

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2022.

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