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REGIONALTRIALCOURT OF BATANGAS
FOURTH JUDICIAL REGION
BRANCH_____
BATANGAS CITY
REBECCA Z. BELO,
Plaintiff.
CIVIL CASE NO.____________
--versus-For Collection of Sum of Money
FRIDA Y. CALAYAN,
Defendant.
x------------------------------------------x
COMPLAINT
PLAINTIFF, thru counsel, to this Honorable Court respectfully
alleges that:
The Parties
1. Plaintiff is a Filipino, single, of legal age, and resident of Mypa
Building, Diego Silang Street, Batangas City;
2. Defendant is also a Filipino, married, of legal age, and resident of 678
Rizal St., Lipa City where she may be served with summons and other
court processes;
The Facts
3. Defendant and plaintiff entered into an agreement embodied in a
contract executed in Batangas City on October 1, 2013, a copy of
which is attached as ANNEX A and made an integral part of this
complaint, whereby, for the amount of TWO MILLION FIVE
HUNDRED THOUSAND PESOS (Php2,500,000.00), the defendant
would deliver to the plaintiff one (1) unit of SUCTIOFAT-1000 laser
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3,
2013
amounting
to
ONE
MILLION
PESOS
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Prayer
WHEREFORE, plaintiff respectfully prays of this Honorable Court
that judgment be rendered annulling the contract entered into by and
between plaintiff and defendant, and ordering defendant to pay the plaintiff:
1. The sum equivalent of the down payment amounting to ONE MILLION
PESOS (Php1,000,000.00) plus legal interest;
2. The sum of THREE MILLION FIVE HUNDREDS THOUSAND PESOS
(Php3,500,000.00) as lost earnings from December 2013 to March
2015;
3. The
sum
of
ONE
HUNDRED
FIFTY
THOUSAND
PESOS
CROIP.BLAN
Counsel for Plaintiff
Attorneys Roll No.: 97507
IBP No.: 6260901/03/13
PTR No.: 3161201/03/13
MCLE Compliance No.: IV0001003
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Page 4 of 5
CROIP.BLAN
Notary Public
Attorneys Roll No.: 97507
IBP No.: 6260901/03/13
PTR No.: 3161201/03/13
MCLE Compliance No.: IV0001003
Doc. No. 3
Page No. 45
Book No. VI
Series of 2015
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