Republic of the Philippines

Municipal Trial Circuit in Cities

Branch __, 8th Judicial Region
Tacloban City
Pedro Gil,
Plaintiff,
- vs -

Civil Case No. 123456

For: Collection
Money

of

Sum

of

Maria Ozawa,
Defendant
x----------------------------x
COMPLAINT
COMES NOW plaintiff, by counsel, unto this Honorable Court
most respectfully alleges:
1. That plaintiff is of legal age, married, Filipino with residence
at Brgy. 96, Calanipawan, Tacloban City. They may be served
with notices, orders and processes of this Honorable Court
through undersigned counsel.
2. That defendant Maria is of legal age, single, Filipino and
with residence at Brgy. 22, Burgos Street Tacloban City, where
she may be served with summons.
3. That on August 24, 2014, the defendant obtained a loan
from the plaintiff for a sum of Three Hundred Thousand Pesos
(P300,000.00) with interest at 12 % per annum, and on the

same day, in the city of Tacloban, for value received, the

defendant executed a promissory note in favor of the plaintiff
in the sum of Three Hundred Thousand Pesos (P300, 000.00)
to be fully paid on or before 31 August 2015;

4. That a true copy of the said promissory note is hereto

attached as ANNEX A forming an integral part hereof.
5. That the due date, August 31, 2015, of said promissory note
arrived and yet the defendant failed to pay, despite several
verbal and written demands. Therefore plaintiff, through his
counsel, sent a demand letter to defendant demanding him to
pay the principal amount of Three Hundred Thousand Pesos
(P300, 000.00).
6. That a faithful reproduction of the aforementioned demand
letter is hereto attached as ANNEX B forming an integral part
hereof.
7. Plaintiff coursed her complaint thru the Barangay Lupon of
Barangay 22, Tacloban City. After several hearings, the
defendant still refused to comply with her obligation. As a
result, the Barangay issued a Certificate to file action herein
attached as ANNEX C.
8. That all other subsequent demands made by the plaintiff
were all met by adamant refusal by defendant.

PRAYER
WHEREFORE, after hearing and trial, judgment is rendered in
favor of plaintiff and against defendant, by:
1. Directing the defendant to pay plaintiff the total amount
of Three Hundred Thousand Pesos (P300,000.00).
2. Directing the defendant to pay the plaintiff exemplary
damages to Twenty Thousand Pesos (20,000) and costs of
the litigation.
3. Directing the defendant to pay the plaintiff's attorney's
fee amounting to 15,000 php acceptance fee and
1,500php appearance fee per hearing.

Other reliefs and awards that may be applicable are likewise

prayed for.

Tacloban City, Philippines, September 30, 2015

Atty. Juan Dela Cruz

Counsel for plaintiff
PTR No. 00001
IBP NO.00002
Roll No. 123132
MCLE NO. 123

Republic of the Philippines

Province of Leyte
City of Tacloban

}
} S.S.
}

x-----------------------------------x

VERIFICATION
CERTIFICATION OF NON-FORUM SHOPPING
I, PEDRO, of legal age, married, Filipino, with residence at
Tacloban City after having sworn to in accordance with law,
hereby depose and state:
1. That I am the Plaintiff in the above-entitled civil case.

2. That I caused the preparation of this complaint, and have

read it; and the contents thereof are true and correct of
my personal knowledge and as based on the records on
hand.
3. That I further certify that I have not commenced any
action or filed any claim involving the same issued in any
court, tribunal or quasi-judicial agency, and there is no
other action or claim pending therein; that if there is any
such pending action or claim or similar action or claim is
pending, I shall immediately report that fact to this
Honorable Court, within five (5) days from knowledge
thereof.
IN WITNESS THEREOF, I hereunto affix my signature this 30 th
of September 2015 , Tacloban City, Philippines.
PEDRO GIL
Affiant

SUBSCRIBED AND SWORN TO before me this 3Oth day of

September 2015, here in Tacloban City, Philippines, with
evidence of identity, Drivers License No. HO2-18456-466
issued at Tacloban City, issued on December 30, 2014.

Atty. Juan Dela Cruz

Notary Public Until December 31, 2016
Notarial Commission 2013-05-78
CITY OF TACLOBAN, PROVINCE OF LEYTE

PTR No. 00001

IBP NO. 00002
Roll No. 123132

Doc. No. 45;

Page No. 78;
Book No. 1;
Series of 2015