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counsel, and to this Honorable Court, respectfully alleges: 1. That the plaintiff is of legal age, Filipino citizen and resident of No.7 Agoo Street, Quezon City and the defendant is also of legal age, Filipino citizen and a resident of No. 19 Dagupan Street, Tondo, Manila where he may be served with summons; 2. That on or about January 1, 1983, defendant obtained a loan of P20,000.00 from the plaintiff payable within 90 days from date of receipt at 12% per annum; 3. That said loan, now overdue, is evidenced by a promissory note signed by the defendant, a copy of which is hereto attached as “annex A” and made part of this complaint; 4. That despite repeated demands, both written and oral, defendant has failed and refused to apply said loan; 5. That due to the unjust and unlawful act of the defendant to comply with the said demands, the plaintiff was compelled to institute this action engaging the services of counsel in the amount of P1,000.00 WHEREFORE, it is respectfully prayed that judgment be rendered against the defendant to pay the plaintiff the sum of P20,000.00 plus interest of 12% from the date of the instrument until full amount is payed and attorney’s fees in the amount of P1,000.00 and costs of the suit. Other equitable reliefs are likewise prayed for. ___________________, 1991, Quezon City.
________________________ Attorney for Plaintiff ________________________ Address
As Second Cause of Action: 1. That on the 19th of August 1983. 1983. Plaintiff hereby incorporates the allegations of paragraph 1 of the first cause of action. That on the 11th day of June.R. nor any part thereof or interest thereon. Malate. Same as paragraph 3 of the first cause of action) WHEREFORE. it is respectfully prayed that judgment be rendered in favor of Plaintiff and against defendant for the sum of (the total amount of the promissory notes) with interest at the rate of six percentum per annum on each of the aforesaid notes. .R. PLAINTIFF.P. and that defendant is a resident of 486 Tenesee._____ Date & Place of Issue_____ COMPLAINT (SEVERAL CAUSES OF ACTION) Plaintiff Alleges: First Cause of Action 1. in the following words and figures. No. 2. No.______ Date & Place of Issue______ IBP O.T. 2. until paid. further prays for such other relief as this Honrable Court may deem just and equitable in the premises. interest at the legal rate on the interest due from the time of the filing of the complaint and attorney’s fees plus costs. defendant executed and delivered to the plaintiff his promissory note in the following words and figures. Manila where he may be served with summons. defendant executed and delivered to plaintiff a promissory note. That the plaintiff is a resident of the City of Manila. to wit: (insert copy of promissory note) 2. That defendant has not paid promissory note. to wit: (insert copy of the promissory note or use as Annex) 3.
. October 10. 1987.Manila.T. No. Philippines.__ & IBP Receipt No. Manila P. JOSE CRUZ Attorney for the Plaintiff 311 Regina Building.R.