Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 66
Cebu City
RONALD, plaintif
FOR: COLLECTION OF SUM OF
MONEY,
DAMAGES
and
ATTORNEYS FEES
- versus -

ARNOLD, defendant
x----------------------------------/
AMENDED PETITION/COMPLAINT
COME NOW PLAINTIFF RONALD, thru the undersigned
counsel, unto the Honorable Court respectfully avers, that:
I
Parties to the case
1. Plaintif Ronald is a Filipino of legal age, married to
Roma Mae and a resident of Barangay Lawaan II,
Talisay City, Cebu, Philippines;
2. Defendant Arnold is likewise a Filipino of legal age,
married to Jenniveve and a resident of Barangay Tisa,
Cebu City, Cebu, Philippines.

II

RONALD vs. ARNOLD

Complaint

Statement of Ultimate Facts

Page 2 of 5

x - - - - - - - - - - - - - - - - - - - -/

1. On February 14, 2000,

the defendant borrowed
money from the plaintif amounting to FIVE
HUNDRED THOUSAND PESOS (PHP 500,000.00)
payable within a period of one year;
2. Plaintif granted the said loan and gave the
defendant FIVE HUNDRED THOUSAND PESOS;
3. Plaintif asked defendant to execute and sign a
promissory note specifying the amount loaned and
the one-year maturity date;
4. Upon the maturity of the loan and Plaintifs demand,
Defendant was not able to pay the said loan;
5. Defendant Arnold refused to pay the said loan and
insisted that he be given a period of one-year to
settle the same by reason of his upcoming Silver
Wedding Anniversary;
6. In view of the Arnolds refusal to settle his
indebtedness, Plaintif caused his lawyer to send a
demand letter requesting for the settlement of
Defendant Arnolds indebtedness in the amount of
FIVE HUNDRED THOUSAND PESOS (PHP
500,000.00) within ten (10) days upon receipt
thereof;
7. In spite of repeated written and oral demands made
by Plaintif Roland, Defendant Arnold ignored the
same and still refused to settle his indebtedness;
Damages
8. Due to the refusal of the Defendant to settle his
indebtedness despite repeated written and oral
demands, herein Plaintif was made to incur litigation
expenses in the amount of TWO HUNDRED
THOUSAND PESOS (PHP 200,000.00), which
includes the filing fees, court fees and other litigation
expenses;

RONALD vs. ARNOLD

Complaint

9. So as to prosecute the
present case, herein
x - - - - - - - - - - - - - - - - - - - -/
Plaintif was constrained
to secure the services of
a lawyer and was made
to pay the amount of FIFTY THOUSAND PESOS
(PHP 50,000.00) and obligated himself to pay his
counsel FIVE THOUSAND PESOS (PHP 5,000.00)
per hearing;
Page 3 of 5

III
PRAYER

RONALD vs. ARNOLD

Complaint
Page 4 of 5

x - - - - - - - - - - - - - - - - - - - -/

WHEREFORE, it is respectfully
prayed that,

1. After trial, that an order be issued for the payment of

the entire debt of FIVE HUNDRED THOUSAND
PESOS (PHP 500,000.00).
2. After trial, that an order be issued ordering the
defendant to reimburse pay the plaintif the amount
of PHP 200,000.00 as actual damages incurred by
the plaintif in pursuing the present case, which is
composed of the various litigation expenses and
court fees;
3. After trial, that an order be issued ordering the
defendant to reimburse plaintif the amount of PHP
50,000.00 and per appearance fee of PHP
2,500.00 per hearing that plaintif incurred and will
incur for the legal services needed in pursuing the
present case.
Plaintif prays for such other relief that is just and
reasonable under the premises.
Cebu City, Philippines. February 25, 2015.

HENRY MIGUEL LUIGI T. FILOTEO

Counsel for the Plaintif
Roll No. 44949
MCLE Compliance Certificate No. IV-1234567
PTR No. 1938715, 1/07/15, B.C.
IBP Lifetime No. 659241
ANGEL LOCSIN FILOTEO LAW OFFICE
Rm. 205, 2nd Floor, OngHoc Bldg.
Banilad, Cebu City

VERIFICATION & CERTIFICATE OF NON-FORUM

SHOPPING

RONALD vs. ARNOLD

Complaint

I, ROLAND, Filipino of legal

age, and a resident of Barangay
x - - - - - - - - - - - - - - - - - - - -/
Lawaan II, Talisay City, Cebu,
Philippines, after having sworn to
in accordance with law, hereby
depose and say:
Page 5 of 5

1.
2.
3.

4.

5.

6.

That I am the plaintif in the present case for

For the Collection of Sum of Money, Damages,
Attorneys Fees;
That I have caused the preparation and filing of
the foregoing amended complaint/petition;
that I have read the allegations in the amended
complaint/petition and the same are all true and
correct based on my personal knowledge and
upon authentic records and documents;
That I have not commenced any other action
involving the same issues in the Supreme Court,
Court of Appeals or diferent divisions thereof, or
any other tribunal or agency;
No such action or proceeding is pending in the
Supreme Court, the Court of Appeals, or diferent
Divisions thereof, or any other tribunal or
agency;
That if I should thereafter learn that a similar
action or proceeding has been filed or is pending
before the Supreme Court, the Court of Appeals,
or diferent divisions thereof, or any other
tribunal or agency, I undertake to promptly
inform the aforesaid courts and other tribunal or
agency thereof within five (5) days therefrom.

IN WITNESS WHEREOF, I hereunto set my hand this

25th day of February 2015 in the City of Cebu, Philippines.
ROLAND
CTC No.02356215
Place of Issue Talisay City
Date of Issue January 16, 2015
SUBSCRIBED AND SWORN to before me this 25th day of
February 2015 in the City of Cebu, Philippines.