Complaint - Collection for Sum of Money
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Transcript of Complaint - Collection for Sum of Money
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8/18/2019 Complaint - Collection for Sum of Money
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REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Branch __, MANILA
ALEXANDER SISON
Plaintiff,
Civil Ca! N"# _________
$v!r%$ F"r& S%' "( M"n!)
JUAN JAMERO
Defendant.
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C O M P L A I N T
Plaintiff, through the undersigned counsel unto this Honorable Court,
hereby respectfully states as follows:
1) Plaintiff, is of legal age, single, Filipino, and a resident of 111
Libertad t., a!paloc, "etro "anila, Philippines while the Defendant isalso of legal age, single, Filipino, and a resident of ### $uan Luna t.,
%ondo, "etro "anila, Philippines where su!!ons and court proceedings
!ay be ser&ed'
#) %hat, the Defendant borrowed fro! the Plaintiff a su! of !oney
a!ounting to (* "+LL+( pesos P1,---,---.--), with 1# interest per
annu!, as e&idenced by a Pro!issory ote herein attached as /0nne 02
and for! an integral part of the co!plaint'
3) %hat, the indebtedness of the Defendant has beco!e due and
de!andable on $anuary 3, #--4, a year after it was pro!ised in the
pro!issory note'
5) %hat, despite repeated &erbal and written de!ands !ade by the
Plaintiff upon the Defendant, the Defendant has failed to fulfill his
obligation as e&idenced by /0nne 62'
7) %hat, the Plaintiff in order to enforce his rights and interests, hassought the ser&ice of a legal counsel with attorney8s fees a!ounting
P97,---.-- and an appearance fee of P3,---.-- for e&ery appearance in
court as e&idenced by /0nne C2'
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*HEREFORE, pre!ises considered, it is hereby respectfully prayed
before the Honorable Court to render decision in fa&or of the plaintiff and
order the Defendant to pay the following'
a) u! of (ne "illion Pesos P1,---,---.--), plus interest at the rate
of %wel&e Percent 1#) per annu! as stipulated upon in the Pro!isory
ote'
b) "oral da!ages, ee!plary da!ages, at the sound discretion of the
court'
c) 0ttorney8s fees a!ounting to P 97,---.-- plus 0ppearance Fee at
the rate of P 3,---.-- per court hearingconference'
d) Litigation epenses.
(ther reliefs and re!edies dee!ed ;ust and e
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REPUBLIC OF THE PHILIPPINES
CIT- OF MA.ATI SS#
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/ERIFICATION AND CERTIFICATION
+, 0leander ison, Fillipino, of legal age, single and a resident of of
111 Libertad t., a!paloc, "etro "anila, Philippines, after duly being
sworn to in accordance with law, hereby depose and say:
%hat + a! the Petitioner of the abo&e?entitled case' %hat + ha&e caused
the preparation of the abo&e Petition and + ha&e read the sa!e and =nows the
contents thereof' %hat the allegations contained therein are true and correct
of !y own personal =nowledge.
%hat + further certify that: a) + ha&e not theretofore co!!enced any
action or filed any action or clai! in&ol&ing the sa!e issue in any court,
tribunal or
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8/18/2019 Complaint - Collection for Sum of Money
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SUBSCRIBED AND S*ORN to before !e, this #7th day of $anuary
#--4 at "a=ati City, "etro "anila, Philippines, affiant ha&ing ehibited to
!e his %+ bearing o. -1?5#@?#79?471 issued on $une 3, #--A at "etro
"anila, Philippines.
ATT-# MA-REN P# ABUCION
otary Public
Bntil Dece!ber 31, #-1-
P% o. 1#357@9
+6P o. 7A@39
oll o. 1#357@
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