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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT
Manila

MELVIN LANTION,
Complainants, CIVIL CASE NO. ___
FOR COLLECTION OF SUM
WITH DAMAGES
-versus-

EVANGELINE GARCIA,
Defendant.
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COMPLAINT

Complainants, unto the Honorable Court, most respectfully aver:

1. Complainants are of legal age, Filipino citizens and residents of 28 Street

North, Sampaloc, Manila, while defendant is of legal age, Filipino and a resident of 46

Bacani St., Sampaloc Manila where she may be served with summons and other

processes of the Honorable Court;

2. Defendant executed a Promissory Note in favor of the complainants herein

whereby she obliged to pay the sum of TEN THOUSAND SIX HUNDRED PESOS

(P10,600.00) with 10% interest per month on or before March 25, 2004; A copy of the

Promissory Note is attached as Annex “A” hereof;

3. That notwithstanding demands, orally and in writing, made on the defendant to

pay her obligation, she refused to pay the same; A copy of the last demand letter is

attached as Annex “B” hereof;

4. That in order to settle the matter, Complainants brought the case before the

Lupong Tagapamayapa of Barangay La Torre, Sampaloc, Manila, but to no avail; hence,

a Certification to File Action was issued, a copy of which is attached as Annex “C”

hereof;

5. That in order to ventilate complainants’ rights, they were forced to hire the

services of counsel whom they promised to pay the sum of P3,000 by way of acceptance

fee and P500.00 per court appearance;

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6. That because of the malicious actuation of the defendant herein, complainants

suffered sleepless nights and besmirched reputation for which reason defendant should be

ordered to pay the sum of P10,000 by way of moral damages;

7. That in order for others not to emulate the malicious actuations of the

defendant, she should likewise be ordered to pay the sum of P10,000 by way of

exemplary damages.

WHEREFORE, premises considered, it is respectfully prayed the Honorable

Court, that after due notice and hearing, judgment be rendered in favor of the

complainants:

a. Ordering the defendant to pay the sum of TEN THOUSAND SIX HUNDRED
PESOS (P10,600.00) plus 10% interest per month as stipulated until the
amount is fully paid or as may be reduced by the Honorable Court in its
discretion;

b. To pay the sum of P3,000 by way of attorney’s fees and P500 per court
appearance;

c. To pay the sum of P10,000 by way of moral damages and P10,000 by way of
exemplary damages;

d. To pay the cost of the suit.

Complainants pray for such other relief just and equitable in the premises.