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REPUBLIC OF THE PHILIPPINES


_______________ TRIAL COURT
____ JUDICIAL REGION
Branch ____
___________________

__________________________,
Plaintiff

- versus -
CIVIL CASE NO. ________________
For: SUM OF MONEY
__________________________,
Defendant

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

COMPLAINT

Plaintiff, through the undersigned counsel, to this Honorable Court, respectfully


alleges that:

1. Plaintiff is of legal age, Filipino citizen, residing at ____________________,


while defendant is likewise of legal age and a resident of
________________________, where he/she may be served with summons;

2. On ________________________, defendant borrowed from the plaintiff the


amount of __________________________, subject to interest at the rate of __%
per month, payable on __________________, as evidenced by an agreement
executed on _____________, a copy of which is hereto attached as Annex “__”
hereof;

3. Defendant failed to pay the said loan and interests thereon on the due date thereof,
and continues to fail to pay the same until the present, despite demands of the
plaintiff;

4. Due to defendant’s unjustified failure to comply with plaintiff’s plainly just and
valid claim, plaintiff was compelled to initiate this action and to retain the
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services of the undersigned counsel and to incur expenses in the amount of


_______________________ as and by way of attorney’s fees.

WHEREFORE, it is respectfully prayed that, after due hearing, judgment be


rendered ordering the defendant to pay the plaintiff the amount of
___________________ with interest thereon at the rate of __% per month from
___________________, 2007 until fully paid, plus the amount of
_____________________ for and as attorney’s fees.

Plaintiff prays for such other and further relief as may be just and equitable under
the premises.

______________________, Philippines, ________________ ____, 2007.

___________________________________
Counsel for Plaintiff
(Address)
(Roll No.; IBP No.; PTR No., date & place issued)
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CERTIFICATION OF NON-FORUM SHOPPING

I, ______________________, plaintiff in the above-entitled case do hereby


certify under oath that:

1. I have not heretofore commenced any action or filed any claim involving the
same issues before any court, tribunal or quasi-judicial agency;

2. To the best of my knowledge, there is no such other action or claim pending


before any other court, tribunal or quasi-judicial agency; and

3. If I should thereafter learn that such other action has been filed or is pending, I
will report such fact to this Honorable Court within five (5) days after learning the
same.

______________________, Philippines, ________________ ____, 2007.

________________________
Affiant

SUBSCRIBED AND SWORN to before me, in the City of _______________, this ____
day of _____________, 2007, the affiant exhibiting to me his Community Tax Certificate
No. _______________ issued at _______________________ on _________________
and Tax Identification No. _________________.

NOTARY PUBLIC

Doc. No. _____;


Page No. _____;
Book No. ____;
Series of 2007.

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