Republic of the Philippines

REGIONAL TRIAL COURT

14th Judicial District
BRANCH 2, Cebu City
Ludica Oja,
Plaintif
-versus-

Civil Case No. 13335

For : Sum of Money

Ren Santos,
Defendant,
x-----------------------------------x

COMPLAINT
PLAINTIFF, by counsel, respectfully states that:
1. Plaintiff Ludica Oja (hereafter Plaintiff ) is a Filipino citizen, of legal age, married
and residing at Banilad, Cebu City, Cebu where he may be served with court processes,
motions, and decision;
2. Defendant Ren Santos (hereafter Defendant) is a Filipino citizen, of legal age, and
residing Talamban, Cebu City, Cebu where he may be served with summons and other court
processes;
3. That on August 1, 2014, defendant executed a promissory note in favor of the
plaintiff in the amount of P500,000 payable within 30 days from the date of the promissory
note (attached as Annex A) which reads as follows:
Manila, Philippines
1 August 2014

date.

I promise to pay Ludica Oja the sum of P500,000 or order within30 days from this

Ren Santos
4. That the 30-day period had elapsed and despite demands made orally and in
writing (attached as Annex B) by the plaintiff, defendant refused and failed to pay the
amount stated in the promissory note.
5. That due to the unjust refusal of defendant to comply with the demands, plaintiff
was compelled to file the instant action engaging the services of counsel in the amount of
P10,000.00.
PRAYER

WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision
directing defendant to pay him FIVE HUNDRED THOUSAND PESOS (P500, 000.00), with legal
interest, as ACTUAL DAMAGES and TEN THOUSAND PESOS (P10, 000.00) as Attorneys Fees.
Plaintiff prays for such other and further reliefs as may be just and equitable reliefs
Cebu City, December 29, 2014
Clark L. Barcelon
Counsel for the Plaintif
Phoenix Sun Business Park E. Rodriguez Jr. Ave., Cebu City, Cebu
Attorney Roll No. 76430
IBP No. 352980 -01/03/2014
PTR No. 45321 01/03/2014
MCLE Compliance No. 11-00043527 Nov 10, 2013

VERIFICATION AND CERTIFICATIONOF NON-FORUM SHOPPING

I, Ludica Oja, Filipino, of legal age, after been duly sworn, depose and state that:
I am the Plaintiff in the forgoing Complaint for Sum of Money.
I caused the preparation of the foregoing Complaint which I have read and
understood.
I hereby affirm that all factual allegations contained in the said Complaint are true
and correct of my own personal knowledge and belief, as well as true and correct basis of
authentic documents and records in my possession.
I further certify that I have not commenced any other action involving the same
issues before the Supreme Court, Court of Appeals or any division thereof or any tribunal or
agency; and to the best of my knowledge no such action is pending before the Supreme
Court, Court, Court of Appeals or any division thereof or any tribunal or agency.
In the event that any action involving the same should be made known, I hereby bind
myself to report the same within five (5)days from knowledge thereof to this Honorable
Court.
WITNESS WHEREOF, I hereunto set my hand this 14th day of December, 2014 at
Cebu City, Cebu, Philippines.
Ludica B. Oja
Plaintif
SUBSCRIBED AND SWORN TO before me this ______ day of ______, ______ at
Quezon City, affiant having exhibited to me her CTCNo. ___________ issued on __________ at
__________.
NOTARY PUBLIC
Doc. No._____
Page No. ____

Book No. _____

Series of _____