Sample Complaint for Collection for a Sum of Money PDF

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Republic of the Philippines 6 TH JUDICIAL REGION Regional Trial Court Branch _____ Iloilo CityMIA C. SANCHEZ, Civil Case No. _____ Plaintiff FOR: COLLECTION FOR A SUM OF MONEY WITH DAMAGES versus - PAOLO D. CRUZ, Defendant x -----------------------xCOMPLAINTPlaintiff, through the undersigned counsel...

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Republic of the Philippines 6TH JUDICIAL REGION Regional Trial Court Branch _____ Iloilo City

MIA C. SANCHEZ, Plaintiff

Civil Case No. _____________ FOR: COLLECTION FOR A SUM OF MONEY WITH DAMAGES

- versus PAOLO D. CRUZ, Defendant x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court, hereby respectfully avers: 1. That plaintiff is of legal age, Filipino, married, and a resident of Alta Tierra Village, Jaro, Iloilo City, Philippines while the defendant is also of legal age, married, Filipino and a resident of Brgy. Dungon A., Jaro, Iloilo City, Philippines where summons and court processes may be served; 2. That on February 14, 2013, the defendant borrowed from the plaintiff a sum of money amounting to One Million Pesos (PhP1,000,000.00) with an agreed interest of five percent (5%) per month as evidenced by a promissory note herein attached as Annex “A” and form an integral part of this complaint; 3. That as shown in the attached promissory note, the indebtedness of the defendant has become due and demandable on February 14, 2014; 4. That despite plaintiff's repeated demands, both written and verbal, defendant failed, neglected and refused to fulfill obligations without just and valid grounds to the continued damage and prejudice of plaintiff, as evidenced by Annex “B” – Demand Letters; 5. That the plaintiff in order to enforce his rights and interests, has sought the services of a legal counsel with attorney’s fees amounting to One Hundred Thousand Pesos (PhP 100,000.00) and an appearance fee of Two Thousand Pesos (PhP 2,000.00) per hearing as evidenced by Annex “C” – Contract for Legal Services;

6. That the plaintiff has paid for litigation expenses amounting to Twenty Thousand Pesos (PhP 20,000.00) as evidenced by Annex “D” – Official Receipt; 7. That the plaintiff has suffered moral damages at the sum discretion of the Honorable Court;

WHEREFORE, premises considered, it is hereby respectfully prayed before the Honorable Court to render decision in favor of the plaintiff and order the defendant to pay the following: a. the sum of One Million Pesos (PhP 1,000,000.00) plus interest at the rate of five percent (5%) per month as stipulated in the promissory note; b. moral damages, exemplary damages at the sum discretion of the court; c. attorney’s fees amounting to One Hundred Thousand Pesos (PhP 100,000.00) and an appearance fee of Two Thousand Pesos (PhP 2,000.00) per hearing d. litigation expenses amounting to Twenty Thousand Pesos (PhP 20,000.00). Other reliefs and remedies deemed just and equitable under the foregoing premises are likewise prayed for. Iloilo City, December 6, 2014.

ATTY. VINCENT ENRIQUE A. VARONA Counsel for Petitioner Varona Law Office, Alta Tierra Village, Jaro, Iloilo City Roll of Attorneys No. 54321 PTR NO. 654321, 01/06/14, Iloilo City IBP NO. 123456, 01/04/14, Iloilo City MCLE Comp. No. IV-0009876, 01/02/14...