REPUBLIC OF THE PHILIPPINES

6th Judicial Region

Regional Trial Court
Iloilo City

ABC FINANCE AND LENDING

CORPORATION represented by
MS. DIANE IRADA, President
Plaintiff.
-versus-

CIVIL CASE NO.

For: Sum of money with Damages

MS. MELANIE LEE

Defendant.
x------------------------------------------------x

C O M PLAI N T
Plaintiff, through the undersigned counsel and to this Honorable Court,
respectfully aver that:
1. That plaintiff is a finance and lending corporation duly organized and
existing under the Laws of the Philippines, having its principal office at
ABC Bldg, Lopez Jaena St., Jaro , Iloilo City;
2. That defendant is Ms. Melanie Lee, of legal age, Filipino citizen and
residing at Tabuc Suba, Jaro, Iloilo City, where she may be served with
summons and other Court processes;
3. That on September 15, 2015, the defendant obtained a loan from the
plaintiff in the sum of Three Hundred Fifty Thousand Pesos
(P350,000.00) Philippine Currency, with the following terms and
conditions among others:
a. The principal loan obligation shall be payable in Two (2) Months
from time of execution of the agreement;
b. The principal loan obligation shall incur an interest of 36% per
month compounded; and
c. The loan was to mature on 31 November 2015.

4. That the said loan is now overdue and despite demands made orally and
in writing by the plaintiff, defendants spouse refused and failed to pay
the amount as evidenced by the Demand Letter send by the Banks Legal
Counsel, dated December 01, 2015, photocopy of which is hereto
attached as Annex A and made an integral part hereof.

P R AYE R
WHEREFORE, it is most respectfully prayed of this Honorable Court
that after due hearing, judgment be rendered in favor of plaintiff and against the
defendant in this manner.
1.

Ordering the defendant to pay plaintiff the amount of Three

Hundred Fifty Thousand Pesos (P350,000) Philippine Currency,
with interest thereon at the rate of 36% per month, compounded
from September 15,2013, and until the same is fully paid; and

2.

Ordering the defendant to pay the cost of this suit.

Plaintiff likewise prays for such other and further relief or reliefs as this
Honorable Court may deem just and equitable in the premises.
Iloilo City, Philippines, December 8, 2015.

RUZZEL DIANE ODUCADO

Counsel for the Plaintiff.
CDE Building
Valeria St., Iloilo City
VERIFICATION AND CERTIFICATION OF
NON-FORUM SHOPPING
I, Diane Irada, of legal age, President of ABC Lending Corporation
located at ABC Bldg, Lopez Jaena St., Jaro , Iloilo City, under oath, do hereby
depose states that:
1. I am the complainant in the said case;
2. I have caused the preparation of the same and I attest to the veracity
of all the allegations stated herein;

3. I have read and understood all the allegations herein and that I attest
to the authenticity and veracity of all the documents attached herein
as based on existing and authentic records;
4. I further certify that I have not commenced or filed any claim
involving the same issues herein with any other Court. Tribunal or
Quasi-Judicial Agency or I am not aware of any such other case or
claim pending before any other court, tribunal or quasi-judicial
agency; and
5. Should I thereafter learn of the filing or pendency of such similar
action or claim, I will inform this Honorable Court of such fact
within five (5) days from knowledge thereof.
IN WITNESS WHEREOF, I have hereunto affixed my hands this 8th
day of December 2015 at Iloilo City, Philippines.
Diane Irada
Affiant
SUBSCRIBED and SWORN TO before me this 8th day of December
2015 at Iloilo City, Philippines, affiant exhibiting to me her TIN 1234-1234-12
issued on 20th day of March 2010 at Iloilo City, Philippines.
NOTARY PUBLIC
Until December 31, 20__
Roll of Attorneys No.
PTR No.
IBP No.
MCLE No.

Doc. No. __________

Page No. __________
Book No. __________
Series of 2015

Date: December 1, 2015

To:

Ms. Melanie Lee

Brgy. Tabuc Suba
Jaro, Iloilo City
DEMAND LETTER

Ms. Abucion,
Good day!
I, Anna Reyes, write to you today to remind you of the loan agreement
we entered into on September 15, 2015, in the amount of Php350,000,000.
According to the terms of the promissory note you executed, payment would be
made on or before November 30, 2015.
Consider this correspondence as a formal demand for your compliance
with the abovementioned loan agreement. Please make the payment of the
outstanding balance of Php 350,000.00 not later than one week from the receipt
of this letter. You may pay the amount to me personally, or thru bank deposit at
Banco De Oro Account No. 1234-5678-90 under the name Anna Reyes.
I hope for your swift compliance. If not, I regret to say that I would be
forced to take legal action in order to protect my own interests. You may
disregard this letter if payment has been tendered at the time of receipt of the
same.
Thank you.

Respectfully,
ANNA B. REYES