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- versus –
COMPLAINT
2.That on November 10, 2016, the Defendant obtained from and was
granted a loan accommodation by the Plaintiff in the principal amount of
One Million Pesos (Php 1,000,000.00) with an agreed interest of five
percent (5%) per month as evidenced by a promissory note herein
attached as Annex “A” and form an integral part of this complaint;
5.That the plaintiff in order to enforce her rights and interests, has
sought the services of a legal counsel with Attorney’s Fees amounting to
One Hundred Thousand Pesos (Php 100,000.00), ten percent (10%) of
the amount of the total amount due from Defendant to Plaintiff as
evidenced by Annex “C”- Official Receipt.
PRAYER
Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.
(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.
PROMISSORY NOTE
P__1,000,000.00__
FOR VALUE RECEIVED, I promise to pay without need of demand to the order of
MS. MARIA ANNA C. SANTOS__, at her residence at _Escarrilla Subdivision, Mandurriao,
Iloilo City__, the principal amount of PESOS:
__ONE MILLION PESOS________ (P_1, 000, 000.00__), on or before __November 11,
2017___.
_____________________ _________________________
Annex “B-2”
15 November 2017
DEMAND LETTER
Sir:
We write in behalf of our client, MS. MARIA ANNA C. SANTOS, the matter of your
non-payment of your obligation.
Records disclose that you have an outstanding obligation with our client in the amount of
Php 1,200,000.00 inclusive of interest and surcharges. Despite repeated demands, you
failed and continuously fail to pay the aforesaid amount.
Accordingly, FINAL DEMAND is hereby made upon you to settle the amount
of Php1,200,000.00 within FIFTEEN (15) days from receipt of this letter. Otherwise, we
will be constrained to file the necessary legal action against you to protect the interest of
our client.
We trust that you will give this matter your prompt and preferential attention to avoid the
expense and inconvenience of litigation.
Truly yours,
20 April 2017
Greetings!
I write to you today to remind you of the loan agreement we entered into on
November 10, 2016, in the amount of Php 1,000,000.00. According to the promissory note
you executed, payment would be made on or before November 11, 2017. As of writing
this letter, I have only Php 200,000.00 from you, which were paid last January 5, 2017.
Unless payment of at least fifty percent (50%) of the Outstanding Balance of Php
800,000.00 plus interests is received by us in within ten (10) days from receipt of this letter,
we will have no alternative but to exercise whatever rights and remedies we have under the
law to enforce such payment, including but not limited to institution of legal proceedings
against you to recover the above amount, together with accrued interest and legal expenses.
Thank you.
Respectfully,
OFFICIAL RECEIPT
15 December 2017
This is to certify that I, Ms. Janina P. Samson, has received an amount of One
Hundred Thousand Pesos ( Php 100,000.00) from Maria Anna C. Santos as payment for
the legal services to be rendered by Atty. Louise Mikhaela Rose L. Escarrilla.
JANINA P. SAMSON
Secretary
ETC Law Office