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Repubic of the Philippines

Regional Trial Court


5TH Judicial Region
Branch 16
Tabaco City

Juan Dela Cruz, Plaintiff


-versus- FOR: Nonpayment of the sum of
Php 1,000,000.00, due and
demandable as evidenced by a
promissory note.

Maria Clara, Defendant


x-----------------------------x

COMPLAINT

1. I, Juan Dela Cruz, Filipino, of legal age, single, and a resident of No. 5
Happy Homes, Tabaco City, Philippines, after being sworn to in
accordance with law, depose and state:

2. That I know the person of Maria Clara, who is a resident of 234 Vel
Amor Subdivision, Legazpi City, Philippines, where she may be served
with summons;

3. That on or about March 1, 2014, at Tabaco City, Philippines, the said


Maria Clara obtained a loan from the plaintiff in the amount of Php
1,000,000.00 payable 1 (one) year after date of receipt.

4. That issued in my favor a promissory note in the amount of Php


1,000,000.00 as evidence for the loan accommodation which I have
extended to her. The said promissory note was issued by the said
Maria Clara at . 5 Happy Homes, Tabaco City;

5. That at the time said Maria Clara issued and delivered the promissory
note to me, she made the assurance and representation that the
amount due will be paid by her 1 (one) year after issuance thereof.
Attached herewith, to form an integral part hereof, is a copy of the
said promissory issued by the defendant, as Annex "A.

6. However, after the lapse of 1 (one) year, the time when the loan was
then due and demandable, the defendant failed to settle her
obligation, despite repeated oral demands;

7. As such, written demand for the payment of the amount due was sent
to her, but the defendant still failed to settle her obligation. Attached
herewith, to form an integral part hereof, is a copy of the said demand
letter issued by me for the defendant, as Annex "B.
8. That due to the noncompliance of the defendant with the said
demands, the plaintiff was then compelled to institute this action
engaging the services of a counsel in the amount of Php 5,000.00.

PRAYER

WHEREFORE, the foregoing considered, it is respectfully prayed of this


Honorable Court after hearing on the merits, that:
a. Defendant be ordered to pay the sum of ONE MILLION PESOS (Php
1,000,000.00);
b. Defendant be ordered to pay attorneys fees and the costs of this suit.

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

(Sgd.) JUAN DELA CRUZ


Affiant

SUBSCRIBED AND SWORN to before me this 30th day of September, 2015


in Legazpi City, Philippines. I hereby certify that I have examined the Affiant
and that I am fully satisfied that he has voluntarily executed and understood
the contents of his Complaint.

JENNINE R. ORIBIANA
NOTARY PUBLIC
UNTIL DEC. 21, 2015
COMMISSION NO. 20
PTR . NO. 277277 JAN. 5, 2015
IBP NO. 98769876 JAN. 5, 2015
ATTY. ROLL NO. 977277
PVLB BLDG, LORENZO ST.
TABACO CITY

Doc. No. 101;


Page No. 16;
Book No. LXXXV;
Series of 2015.