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.

    X$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$X

    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#

    X$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$X

    /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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    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

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    oll o. 1#357@

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