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COMPLAINT
Plaintiff, thru the undersigned Counsel, unto this Honorable Court,
respectfully alleges:
PRAYER
WHEREFORE, after hearing and trial, judgment is rendered in favor
of the plaintiff and against the defendant, ordering the latter the following
1. To pay the plaintiff the unpaid principal amount of Seven Hundred
Thousand Pesos (P700, 000.00) plus Twenty One Thousand
Pesos (P21, 000.00) representing the total unpaid monthly
interestand Seventy Thousand Pesos (P70, 000.00) representing
the penalty.
2. Attorneys fees equivalent to Ten Percent (10%) of the total
amount claimed.
3. Costs of litigation.
4. Other just and equitable relief.
)
) S.S.
AMERKHAN SABDULA
Affiant
Doc No.
____
Page No. ____
Book No. ____
Series of 2015
January 5, 2014
Zamboanga City
P1,000,000.00
FOR VALUE RECEIVED, I promise to pay without need of demand to the
order of AMERKHAN SABDULA, at his residence in Guiwan, Zamboanga City
Philippines, the principal amount of One Million Pesos (P1,000,000.00), Philippine
Currency, on or before November 5, 2014. In addition to the foregoing, I promise
to pay an interest rate of Three Percent (3%) every month, commencing from
February 5, 2014 until this note is fully paid.
In case of default of payment, I agree to pay a penalty equivalent to Five Percent
(5%) every month based on the total amount due and demandable until fully paid.
Should it become necessary to collect this note with the services of a lawyer, I shall
pay an amount equivalent to Ten Percent (10%) of the amount claimed in the
complaint as attorneys fees, exclusive of costs of litigation and other expenses.
January 5, 2014 at Edding and Associates Law Office, Zamboanga City,
Philippines.
Philippine Currency, on or before November 5, 2014 plus a monthly interest of Three Percent
(3%) amounting to Twenty One Thousand Pesos (P21,000.00).
However, up to the present, you have not acted on our clients demand to pay him the
aforementioned amount. Hence, we are giving you a period of Five (5) days from receipt hereof
to pay him the amount Seven Hundred Thousand Pesos (P700, 000.00) representing the unpaid
principal amount and Twenty One Thousand Pesos (P21, 000.00) representing the unpaid
monthly interest. Please deliver the amount in our office anytime between 9:00 AM-5:00 PM
located at 4A Macrohon Building, Campaner Street, Zamboanga City.
If you still fail and/or refuse to settle the same, we will be constrained to resort to legal action to
protect the interest of our above-named client.
Hoping that you will give this matter your favorable attention and immediate action.
Truly yours,
ATTY. NORBRYAN B. EDDING