Republic of the Philippines

REGIONAL TRIAL COURT

5th Judicial Region
Branch___
NAGA CITY

____________________
Plaintiff,

-vs- Civil Case No. __________

For: Collection of Sum of Money
With Damages

_____________________
Defendant.
x--------------------------------------------x

COMPLAINT

COMES NOW plaintiff, through the undersigned counsel and unto

this Honourable Court most respectfully avers:

1. Plaintiffs is of legal age, Filipino, married and with residence at No.

_______________________. Both have capacity to sue and be
sued;

2. Defendant __________________ of legal age, Filipino, married

and with residence at No. _______________________. Both have
capacity to sue and be sued;

3. Plaintiff is the owner/manager of ____________________

services operating in the _______________ with Office
_______________________________________;

4. That on __________________ the defendant secured the services

of the plaintiff’s _____________________ at the place of business
of the defendant;
5. Defendant then was required to pay the plaintiff to pay the amount
of _____________ for the salaries of the _________ assigned to
the office of the defendant as evidence by the Contact of Services
and promissory note;

6. That in the beginning, the defendant religiously paid the salaries of

the assigned ___________________ to them by delivering the
amount to the plaintiff;
7. That however sometime in ____________________ the defendant
began to fail in the payment of the salaries of the
_____________________ assigned to it by the plaintiff;

8. That because of that the plaintiff sent a demand letter ( Annex ----)
to the defendant requesting payment of the unpaid salaries of the
______________________ assigned to it by the plaintiff;

9. That the defendant failed to settle the obligation which prompted

the plaintiff to send two more demand letters (Annexes -----) but
the plea went to deaf ears;

10. That the plaintiff again let some time to pass before he again
personally asked the defendant to settle its obligation but the
defendant stubbornly failed to oblige;

11. That by reason of the unjustified refusal of the defendant to pay

the plaintiff its obligation, plaintiff suffered actual damages in the
amount of _________________________ as transportation and
representation expenses in trying to extract payment from the
defendant to avoid litigation to which he was unsuccessful;

12. In addition, plaintiffs suffered sleepless nights, wounded

feelings and serious anxiety which if would be quantified would
amount to ________________;

PRAYER
 WHEREFORE, after due notice and hearing, plaintiffs pray that
judgment be rendered ordering defendants to:

A. Pay the plaintiff the amount of ------------- representing the unpaid

obligation of the defendant to the plaintiff in providing
_________________ to the defendant;

B. Order defendants to pay plaintiffs the amount of

________________ as actual damages and ________________
as moral damages;

Other relief just and equitable under the premises are likewise prayed
for.

__________________, Naga City Philippines.

____________________

VERIFICATION/CERTIFICATION

I, __________________, under oath deposes and states:

1. That I am the plaintiff in this case;

2. That I have caused the preparation of this complaint;
3. That the contents stated therein are true and correct of my own
knowledge;
4. That I do hereby certify that I have not commenced any other
action or proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or any other tribunal or agency; that
to the best of my knowledge, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any other
tribunal or agency; that if I should thereafter learn that similar
action has been filed or pending before the Supreme Court, the
Court of Appeals, or any other tribunal or agency, I undertake to
report that fact within five (5) days therefrom to this Honorable
Court.
 IN WITNESS WHEREOF, I have hereunto affixed my signature this
_______ day of ________ 2017 at Naga City, Philippines.

_______________

SUBSCRIBED AND SWORN to before me this _______ day of

_______ 2017 at Naga City, Philippines.