REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Manila, Branch 1

FREDDIE DE ROXAS
Plaintiff,
Civil Case No.13-1314
-versus- For: Sum of Money

ADRIAN C. CABANA
Defendant.

X------------------------------------------X

COMPLAINT

COMES NOW the plaintiff FREDDIE DE ROXAS, by the undersigned

counsel, and to this Honorable Court, respectfully alleges:

1. That the plaintiff is of legal age, Filipino citizen and resident of

No.7 Agoo Street, Quezon City and the defendant is also of legal
age, Filipino citizen and a resident of No. 19 Dagupan Street,
Tondo, Manila where he may be served with summons;

2. That on or about May 22, 2017, defendant obtained a loan of

P20,000.00 from the plaintiff payable within 90 days from date of
receipt at 12% per annum;

3. That said loan, now overdue, is evidenced by a promissory note

signed by the defendant, a copy of which is hereto attached as
annex A and made part of this complaint;

4. That despite repeated demands, both written and oral, defendant

has failed and refused to apply said loan;

5. That due to the unjust and unlawful act of the defendant to comply
with the said demands, the plaintiff was compelled to institute this
action engaging the services of counsel in the amount of P1,000.00

PRAYER

WHEREFORE, it is respectfully prayed that judgment be rendered against the

defendant to pay the plaintiff the sum of P20,000.00 plus interest of 12% from the date
of the instrument until full amount is paid and attorneys fees in the amount of P1,000.00
and costs of the suit.

Other equitable reliefs are likewise prayed for.

September 29, 2017, Quezon City.

 JIMMY AGLUTAY
Counsel for the Plaintiff
Roll No. 67730
IBP No. 9789 (Lifetime) Manila
MCLE Compliance No. III-000143
0PTR No. 11612345-6-7-2016-Manila
Telephone No. (032) 817-3255
E-mail Address: jaglutay@gmail.com

VERIFICATION AND CERTIFICATION

(REPUBLIC OF THE PHILIPPINES

City of Quezon City ) S.S.
x-----------------------x

I, Freddie de Roxas, of legal age, Filipino, single, and a resident of No.7 Agoo
Street, Quezon City, after being sworn in accordance with law, hereby depose and say:

That I am the Plaintiff in the above-entitled case; That I have caused the
preparation of the above Complaint and I have read the same and know the contents
thereof; That the allegations contained therein are true and correct of my own personal
knowledge.

That I further certify that: (a) I have not theretofore commenced any other action or
proceeding or filed any claim involving the same issues or matter in any court, tribunal, or
quasi-judicial agency and, to the best of my knowledge, no such action or proceeding is
pending therein; (c) if I should thereafter learn that the same or similar action or proceeding
has been filed or is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5) days
therefrom to the court or agency wherein the original pleading and sworn certification
contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 29th day of

September, 2017 at Quezon City, Philippines.

Freddie de Roxas
AFFIANT

SUBSCRIBED AND SWORN to before me, this 29th day of September, 2017, by
Freddie de Roxas who exhibited to me her Community Tax Certificate No. 23327052
issued at City of Quezon City, Philippines on 28th day of September, 2017.

JERICHO R. CRUZ
Notary Public
Until December 31, 2018
Roll No. 47714
IBP No. 9899 (Lifetime) Manila
MCLE Compliance No. III-000891
0PTR No. 1161033-9-9-2016-Manila
Telephone No. (032) 254-7882
E-mail Address: jccruz@gmail.com

Doc. No. 189;

Page No. 38;
Book No. III;
Series of 2017