Republic of the Philippines

3RD JUDICIAL REGION

Municipal Trial Court in Cities
Branch II
Tarlac City

JUANA B. SANCHEZ, Civil Case No. _____________

Plaintiff FOR: COLLECTION FOR A
SUM OF MONEY
- versus -

MIGUEL D. MONTERO,
Defendant
x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court,

hereby respectfully avers:

1. That plaintiff is of legal age, Filipino, married, and a resident of

Brgy. Maliwalo, Tarlac City, Philippines while the defendant is also of legal
age, married, Filipino and a resident of Brgy. Santo Cristo, Tarlac City,
Philippines where summons and court processes may be served;

2. That on February 15, 2016, the defendant borrowed from the

plaintiff a sum of money amounting to Ten Thousand Pesos (PhP10,000.00)

3. That as shown in the attached demand letter, the indebtedness of the

defendant has become due and demandable on February 15, 2017;

4. That despite plaintiff's repeated demands, both written and verbal,

defendant failed, neglected and refused to fulfill obligations without just and
valid grounds to the continued damage and prejudice of plaintiff, as
evidenced by Annex A Demand Letters;

5. That the plaintiff in order to enforce his rights and interests, has
sought the services of a legal counsel with attorneys fees amounting to Two
Thousand Pesos (PhP 2,000.00) and an appearance fee of One Thousand
Pesos (PhP 1,000.00) per hearing as evidenced by Annex B Contract for
Legal Services;

6. That the plaintiff has paid for litigation expenses amounting to One
Thousand Pesos (PhP 1,000.00) as evidenced by Annex D Official
Receipt;
 WHEREFORE, premises considered, it is hereby respectfully prayed
before the Honorable Court to render decision in favor of the plaintiff and
order the defendant to pay the following:

a. The sum of Ten Thousand Pesos (PhP 10,000.00)

b. Attorneys fees amounting to Two Thousand Pesos (PhP 2,000.00)

and an appearance fee of One Thousand Pesos (PhP 1,000.00) per
hearing

c. Litigation expenses amounting to One Thousand Pesos (PhP

1,000.00).

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

Tarlac City, October 6, 2017.

 VERIFICATION AND CERTIFICATION

I, JUANA B. SANCHEZ, of legal age, Filipino, married, and a

resident of Brgy. Maliwalo, Tarlac City, Philippines, after being sworn in
accordance with law, hereby depose and say:

(1) That I am the Plaintiff in the above-entitled case;

(2) That I have caused the preparation of the above Complaint and I
have read the same and understood the contents thereof;

(3) That the allegations contained therein are true and correct of my
own personal knowledge and based on authentic records.

(4) That I further certify that: 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; 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 6th day

of October 2017 at Tarlac City, Philippines.

JUANA B. SANCHEZ
Affiant
TIN 98895-007; Tarlac City

SUBSCRIBED AND SWORN to before me, this 6th day of

December 2014, affiant exhibiting to me his Tax Identification Card as
shown above below his name as competent evidence of his identity.