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 attorneys 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. attorneys 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

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF ILOILO ) SS.
x----------------------------x
VERIFICATION AND CERTIFICATION
I, MIA C. SANCHEZ, of legal age, Filipino, married, and a resident
of Alta Tierra Village, Jaro, Iloilo City, Philippines, after being sworn in
accordance with law, hereby depose and say:
(1) That I am the Plaintiff in the above-entitled case;
(2) That I have caused the preparation of the above Complaint and I
have read the same and understood the contents thereof;
(3) That the allegations contained therein are true and correct of my
own personal knowledge and based on authentic records.
(4) That I further certify that: I have not theretofore commenced any
other action or proceeding or filed any claim involving the same issues or
matter in any court, tribunal, or quasi-judicial agency and, to the best of my
knowledge, no such action or proceeding is pending therein; if I should
thereafter learn that the same or similar action or proceeding has been filed or
is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5)
days therefrom to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 6th day
of December 2014 at Iloilo City, Philippines.

MIA C. SANCHEZ
Affiant
TIN 98765-003; Iloilo City

SUBSCRIBED AND SWORN to before me, this 6th day of

December 2014, affiant exhibiting to me his Tax Identification Card as
shown above below his name as competent evidence of his identity.

ATTY. VINCENT ENRIQUE A. VARONA

My Commission No. is 58
Expires on December 31, 2015
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

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2014;