REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT OF MANILA
Manila, Branch __

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff ______________ (hereafter Plaintiff) is a Filipino citizen, of legal

age, married and residing at ____________________ where he may be served with
court processes, motions, and decision;

2. Defendant _______________ (hereafter Defendant) is a Filipino citizen,

of legal age, and residing _______________________________ where he may be
served with summons and other court processes;

3. That on August 1, 1990, defendant executed a promissory note in favor

of the plaintiff in the amount of P________ payable within 30 days from the date of the
promissory note (attached as “Annex A”) which reads as follows:

Manila, Philippines
1 August 1990

I promise to pay Juan dela Cruz the sum of P50,000 or order within
30 days from this date.
PEDRO REYES

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 FIFTY THOUSAND PESOS (P50,000.00), with
legal interest, as ACTUAL DAMAGES and TEN THOUSAND PESOS (P10,000.00) as
Attorney’s Fees.

Other just and equitable reliefs are also prayed for.

Place and date.

Signature of Counsel

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