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Complaint for sum of money [1] Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 101, Makati City ESTA PADORA, Plaintiff, - versus MANGGA GANTSO, Defendant. x -------------------------- x COMPLAINT PLAINTIFF, by counsel, respectfully states that: [2] 1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes Park, Makati City; defendant is also a Filipino, of legal age and resident of 6752, Forbes Park, Makati City, where he may be served with summons and other processes. [3] 2. Sometime in January 2005 and over a period of six (6) months, defendant borrowed certain amounts from plaintiff. Defendant promised to pay these amounts on an installment basis monthly. These amounts now total Nine Hundred Thousand Pesos (P900,000.00). [4] 3. Despite repeated demands, both oral and written, defendant failed or has refused to pay any amount to plaintiff as no installment payment has even been made. A copy each of plaintiffs two (2) demand letters is attached as ANNEX A and B. 4. Resort to the Barangay Conciliation process proved fruitless as defendant failed to appear, despite notice on him to appear. Thus, a Certification to File Action, a copy of which is attached as ANNEX C, was issued by the Barangay Chairman. 5. Defendants obligation is due and dema ndable and plaintiff is entitled to the payment of the entire amount of Nine Hundred Thousand Pesos (P900,000.00) plus legal interest. 6. By reason of defendants unreasonable failure or refusal to pay his due and demandable obligation, plaintiff was forced to engage the services of counsel to vindicate his rights thereby committing himself to pay legal expenses amounting to Fifty Thousand Pesos (P50,000.00). [5] WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision directing defendant to pay him NINE HUNDRED THOUSAND PESOS (P900,000.00), with legal interest, as ACTUAL DAMAGES and FIFTY THOUSAND PESOS (P50,000.00) as Attorneys Fees. Other just and equitable reliefs are also prayed for. [6] Quezon City for Makati; 13 April 2007. [7] (Sgd.) ATTICUS FINCH Counsel for Plaintiff [Address] Civil Case No. 000882 For: Sum of Money

PLUS: [8] Verification and Certification against Forum Shopping

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