Republic of the Philippines

11th Judicial Region

REGIONAL TRIAL COURT
Branch _____, Tagum City

__________________

Represented by:

__________________, Civil Case No. _______

Chairwoman of the Board of Directors
Plaintiff, FOR: COLLECTION FOR A
SUM OF MONEY WITH
DAMAGES

-versus-

___________________,
Defendant.

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

COMPLAINT

PLAINTIFF, through the undersigned counsel unto this

Honorable Court, respectfully states that:

1. That plaintiff is of
legal age, Filipino,
married, and a resident of

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Alta Tierra Village, Jaro,
Iloilo City, Philippines
while the defendant is
also
of legal age, married,
Filipino and a resident of
Brgy. Dungon A., Jaro,
Iloilo
City, Philippines where
summons and court
processes may be served;
2. That on February 14,
2013, the defendant
borrowed from the

2|Page
plaintiff a sum of money
amounting to One
Million Pesos
(PhP1,000,000.00) with
an agreed interest of five
percent (5%) per month
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
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the defendant has
become due and
demandable on February
14, 2014;
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;
4|Page
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”
–

5|Page
1. That plaintiff is of
legal age, Filipino,
married, and a resident of
Alta Tierra Village, Jaro,
Iloilo City, Philippines
while the defendant is
also
of legal age, married,
Filipino and a resident of
Brgy. Dungon A., Jaro,
Iloilo
City, Philippines where
summons and court
processes may be served;

6|Page
2. That on February 14,
2013, the defendant
borrowed from the
plaintiff a sum of money
amounting to One
Million Pesos
(PhP1,000,000.00) with
an agreed interest of five
percent (5%) per month
as
evidenced by a
promissory note herein
attached as Annex “A”
and form an
integral part of this
complaint;
7|Page
3. That as shown in the
attached promissory
note, the indebtedness of
the defendant has
become due and
demandable on February
14, 2014;
4. That despite plaintiff's
repeated demands, both
written and verbal,
defendant failed,
neglected and refused to
fulfill obligations without
just and

8|Page
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
9|Page
Thousand Pesos (PhP
2,000.00) per hearing as
evidenced by Annex “C”
–
1. Plaintiff, ____________, a cooperative duly organized
and existing under the Philippine Laws, duly
represented by _____________, Chairwoman of the
Board of Directors, of legal age, Filipino, married, and a
resident of __________________________ while the
defendant is also a Filipino, of legal age and resident of
_____________________, where he may be served
with a summons and other processes;

2. On ________________, the defendant borrowed from

the plaintiff a sum of money amounting to
_________________ to be paid on the following month,
with the agreed interest of five percent (5%) as
evidenced by a loan agreement herein attached as
Annex “A” and form an integral part of this complaint;

3. As shown in the attached Loan Agreement, the

indebtedness of the defendant has become due and
demandable on ________________;

4. Demands were made, through calls and texts, to pay

the loan amount, but all were remained unheeded;

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5. On _______________, for humanitarian consideration,
Plaintiff has given Defendant a chance to pay his
obligation on an installment basis and even lowered the
monthly interest as evidenced by a promissory note
herein attached as Annex “B”;

6. Still, despite Plaintiff’s considerations and demands,

both written and verbal, Defendant failed, neglected,
and refused to fulfill his obligations without just and
valid grounds for the continued damage and prejudice
of Plaintiff, as evidenced by Annex “C”- Demand
Letters;

7. The plaintiff to enforce his rights and interests, has

sought the services of a legal counsel with attorney’s
fees amounting to Two Hundred Thousand Pesos
(Php200,000.00) and an appearance fee of Three
Thousand Pesos (Php3,000.00) per hearing as
evidenced by ANNEX “D”;

8. The Plaintiff has paid for litigation amounting to One

Hundred Thirteen Thousand Three Hundred Ten
Thousand Pesos (Php113,310.00) as evidenced by
Annex “E”- Official Receipt;

9. The plaintiff suffered moral damages at the sum

discretion of the honorable court;

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WHEREFORE, the plaintiff respectfully prays for judgment
in his favor through a Decision directing the defendant to
pay the following:

1. The sum of _________________, plus legal interest

at the rate of five percent (5%) per month as stipulated
in the loan agreement;
2. Exemplary damages of _____________________
and/or at the sum discretion of the court;
3. Attorney’s Fees amounting to TWO HUNDRED
THOUSAND PESOS (Php200,000.00) and an
appearance fee of Three Thousand Pesos
(P3,000.00) per hearing.
4. Litigation expenses amounting to One Hundred
Thirteen Thousand Three Hundred Ten Pesos
(Php113,310.00)

Other reliefs deemed just and equitable under the

foregoing premises are likewise prayed for.

____________________, Date: ______________.

____________________
Counsel for the Plaintiff

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