a.

Complaints/Petition:

FORM NO. 101

For Sum of Money — basis of the claim is Promissory Note executed by the
defendant. This is form is in compliance with the 2019 Amended Rules on
Civil Procedure.

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH ______, ____________CITY

__________________________
Plaintiff,
-versus- CIVIL CASE NO.

For: Sum of Money

_____________________________
Defendant
x ______________________ x

COMPLAINT

PLAINTIFF ________________ by counsel, to this Honorable Court,

respectfully states, that:
1. Plaintiff is a domestic corporation duly organized and existing
under and by virtue of Philippine laws, with principal business address at
_______________________.

2. Defendant is of legal age, Filipino and a resident

_______________; where he may be served with summons and other
processes of this Honorable Court.
3. Plaintiff is engaged in extending cash loan assistance upon
application for personal loan and acceptance of the terms and conditions
thereof. The personal loan is payable on installment basis at such schedule as
may be agreed upon by the plaintiff and its borrower.
On ________________, defendant applied for and was granted a cash loan in
the amount of _____________________ (P__________) including the term
interest, payable in ___________ (___) monthly installments of P upon her
acceptance of the terms and conditions contained in the Promissory Note.
Photocopies of the Application Form and the Promissory Note (PN) are
attached as Annexes _______ and _____.
5. The Promissory Note provides that:
(state here the terms and conditions of the loan as contained in the
promissory note)

5.a (State legal basis: applicable law and jurisprudence)

6. Defendant failed to pay in due time the monthly installments and
was in default since __________.
7. As of ___________________ defendant's outstanding loan
obligation amounts to ________________ which sums are now due and
demandable; a photocopy of the Statement of Account is attached as Annex
__________.
8. Despite several demands made by plaintiff, the last of which was
on ____________, the defendant failed and refused to settle his aforesaid
obligation to plaintiff. A photocopy of which is attached as Annex ______,
and the registry receipt and return card are attached as Annexes __________.
9. Plaintiff will present (name of witness) who will testify on the
following: (briefly state the matters that the witness will testify on, and the
documentary evidence to prove plaintiffs claims)
10. The judicial affidavit of the witness and the documentary evidence
of the plaintiff are attached to this complaint.
11. To protect its interest, plaintiff was constrained to engage the undersigned
counsel for an agreed attorney's fees equivalent to 25% of the total amount
due plus appearance fee for every court hearing, which expenses should be
paid by the defendant.

PRAYER

WHEREFORE, it is respectfully prayed of this Honorable Court that

judgment be rendered against the defendant by ordering him to pay plaintiff,
as follows:
 (state here the reliefs prayed for)

Further, plaintiff prays for other just and equitable reliefs.

(City where counsel's office is located) for (City where court is
located), (date-of-complaint)
Counsel for the Plaintiff
Roll No.
MCLE Compliance No. and date issued
IBP No. date and place issued
PTR No. date and place issued
(Offce address, telephone number; Fax
number; email address
VERIFICATION AND CERTIFICATION
AGAINST FORUM SHOPPING

I, (name and personal circumstance of affiant), after having duly

sworn, depose and say that:
1. I am the (state position in the plaintiff corporation) of the
plaintiff in the above entitled case complaint; and the duly authorized
by the plaintiffs Board of Directors to file, prosecute this case and to
sign and execute this Verification and Certification against forum-
shopping, as evidenced by the Corporate Secretary's Certificate
attached as Annex " " hereof.
2. I caused the preparation of the foregoing complaint;

3. I have read and understood the contents thereof and attest

that the same are true and correct based on genuine/authentic
documents in my possession;

4. Pursuant to the 2019 Amended Rules of Civil Procedure, I

hereby certify under oath that I have not •filed any other case in the
Supreme Court or Court of Appeals or in any of its Divisions, Regional
Trial Courts, Metropolitan and Municipal Trial Court, and any other
quasi-judicial or administrative bodies, tribunal or agencies any similar
case involving the same issues; neither am I aware of any similar case
pending before the aforesaid courts, administrative bodies, tribunals or
agencies involving the same issues raised in the said complaint;

5. Furthermore, I hereby certify that in case I learned or

become aware of any case involving the same issue as the instant case
pending* in any court, administrative bodies, tribunals or agencies, I
undertake to inform the Honorable Court of the pendency of the said
case within a period of five (5) days from the knowledge thereof.

6. That the foregoing compliant is not filed to harass, cause

unnecessary delay, or needlessly increase the cost litigation and that
the factual allegations on the foregoing compliant have evidentiary
support or if specially so, identified will likewise have evidentiary
support after a reasonable opportunity for discovery.

FURTHER, AFFIANT SAYETH NAUGHT.

Affiant

JURAT

(Signature and Seal of the Notary Public)

FORM NO. 1)