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REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT NATIONAL CAPITAL JUDICIAL REGION BRANCH 69, MANDALUYONG CITY

ABC FINANCE AND LENDING CORPORATION represented by Mr. Ang Bee Chin, President and Elizabeth Ngo, Secretary Plaintiffs. -versusCIVIL CASE NO. M-2014-123 For: Sum of money and damages

Mrs. Michelle Green surviving spouse of Mr. Michael Green Defendants. x------------------------------------------------x

COMPLAINT COMES NOW Plaintiff, by counsel, unto this Honorable Court, most respectfully states: 1. That plaintiff is a finance and lending corporation duly organized and existing under the Laws of the Philippines, having its principal office at No.7, Ideal St. Brgy. Addition Hills, Mandaluyong City; 2. That defendant is Mrs. Michelle Green, the surviving spouse of Mr. Michael Green, of legal age, Filipino citizen and residing at Unit 7C Shaw Residenza, Shaw Boulevard, Barangay Addition Hills, Mandaluyong City, where she may be served with summons and other Court processes; 3. That on September 15, 2013, the defendant obtained a loan from the plaintiff in the sum of Seven Hundred Fifty Thousand Pesos (P750,000.00) Philippine Currency, with the following terms and conditions among others: a. The principal loan obligation shall be payable in Three (3) Months from time of execution of the agreement; b. The principal loan obligation shall incur an interest of 36% per month compounded; and c. The loan was to mature on 31 December 2013. 4. That as a security for the loan, Mr. Michael Green has mortgaged by way of Accommodation Mortgage a Condominium in Paranaque City registered under the holding company of Manny Pacman Holding Corporation. As evidence, a Xerox copy of the Accommodation
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Mortgage dated September 15, 2013 is herewith attached and marked as Annex A and made integral part hereof. 5. That Mr. Michael Green died on November 15, 2013. Leaving the loan unpaid. The second paragraph of Sec. 16, Rule 3 of the 1997 Rules Civil Procedure as Amended, provides: Section 16. Death of party; duty of counsel. Whenever a party to a pending action dies, and the claim is not thereby extinguished, it shall be the duty of his counsel to inform the court within thirty (30) days after such death of the fact thereof, and to give the name and address of his legal representative or representatives. Failure of counsel to comply with his duty shall be a ground for disciplinary action. The heirs of the deceased may be allowed to be substituted for the deceased, without requiring the appointment of an executor or administrator and the court may appoint a guardian ad litem for the minor heirs. The court shall forthwith order said legal representative or representatives to appear and be substituted within a period of thirty (30) days from notice. If no legal representative is named by the counsel for the deceased party, or if the one so named shall fail to appear within the specified period, the court may order the opposing party, within a specified time to procure the appointment of an executor or administrator for the estate of the deceased and the latter shall immediately appear for and on behalf of the deceased. The court charges in procuring such appointment, if defrayed by the opposing party, may be recovered as costs. Death certificate of Mr. Michael Green was attached as Annex B. 6. That the said loan is now overdue and despite demands made orally and in writing by the plaintiff, defendants spouse refused and failed to pay the amount as evidenced by the Demand Letter send by the Banks Legal Counsel, dated January 01, 2014, photocopy of which is hereto attached as Annex C and made an integral part hereof.

PRAYER WHEREFORE, it is most respectfully prayed of this Honorable Court that after due hearing, judgment be rendered in favor of plaintiff and against the defendant in this manner. 1. Ordering the defendant to pay plaintiff the amount of Seven Hundred Fifty Thousand Pesos (P750,000) Philippine Currency, with interest thereon at the rate of 36% per month, compounded from September 15,2013, and until the same is fully paid; and Ordering the defendant to pay the cost of this suit.

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Plaintiff likewise prays for such other and further relief or reliefs as this Honorable Court may deem just and equitable in the premises. Quezon City, Philippines, March 31, 2014. GROUP ONE ASSOCIATES LAW OFFICE Counsel for the Plaintiff. 3rd. Floor New Era Building No. 10 Magalang Street, Bgy. Pinyahan, Mandaluyong City For the Firm: Juan Dela Cruz IBP No. 827847, 6/8/11, QC PTR No. 576784, 6/8/11, QC Attorneys Roll No. 374435 MCLE Compliance No. 11-0989699 MCLE Compliance No. 111-006969

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING I, Ang Bee Chin, of legal age, President of ABC Lending Corporation located at No. 7 Ideal Street, Brgy. Additional Hills Mandaluyong City, under oath, do hereby depose states that: 1. I am the complainant in the said case; 2. I have caused the preparation of the same and I attest to the veracity of all the allegations stated herein; 3. I have read and understood all the allegations herein and that I attest to the authenticity and veracity of all the documents attached herein as based on existing and authentic records; 4. I further certify that I have not commenced or filed any claim involving the same issues herein with any other Court. Tribunal or Quasi-Judicial Agency or I am not aware of any such other case or claim pending before any other court, tribunal or quasi-judicial agency; and 5. Should I thereafter learn of the filing or pendency of such similar action or claim, I will inform this Honorable Court of such fact within five (5) days from knowledge thereof. IN WITNESS WHEREOF, I have hereunto affixed my hands this 31st day of March, 2014 at Mandaluyong City, Philippines. Ang Bee Chin Affiant

SUBSCRIBED and SWORN TO before me this 31st day of March, 2014 at Mandaluyong City, Philippines, affiant exhibiting to me her CTC # 2014123456 issued on 20th day of March at Mandaluyong City, Philippines.

NOTARY PUBLIC Doc. No. __________ Page No. __________ Book No. __________ Series of 2014