Republic of the Philippines

Regional Trial Court

Branch 55
Cebu City

Ronald, plaintiff
Accompanied by his Attorney in fact,
Atty. Gregorio D. Baldove III

Civil Case No. 1

-versus-

for: Collection of Sum

of Money

Arnold, Respondent
x-----------------------------------------x

COMPLAINT

COMES NOW, the plaintiff, Ronald together with the undersigned

counsel to this most honorable court, most respectfully avers THAT;
1. The Plaintiff is of legal age, Filipino citizen, and a resident of Barangay
Lawaan II, Talisay City, Cebu.
2. The Defendant is likewise of legal age, Filipino citizen, and a resident of
Barangay Tisa, Cebu City, Cebu where he may be served with summons and
other legal processes
3. On February 14, 2000, the defendant borrowed money from the plaintiff
amounting to five hundred thousand pesos (Php 500,000.00) payable
within a period of one year.
4. The Defendant executed and signed a promissory note specifying the
amount loaned and the one-year maturity.
5. When the maturity date arrived, the defendant failed to pay the said
amount of Php 500,000.00, in breach thereof.

6. As a result, the plaintiff wrote a demand letter asking for the payment of
the entire obligation of Php 500,000.00 within ten (10) days upon its
receipt.
7. Notwithstanding demands, both verbal and written, made upon
defendant, the latter failed and refused and continues to refuse to pay
his lawful obligation.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that judgment be rendered in favor of the plaintiff and
that after judgment;
a. The defendant shall pay the entire debt of five hundred thousand
pesos(Php 500,000.00)
Such other reliefs and remedies under the premises are likewise prayed for.
Talisay City, February 25, 2014.

Atty. Gregorio D. Baldove III

Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Block 7 Lot 67 Deca Homes 4
Bankal, Lapulapu City, Cebu, Philippines

VERIFICATION AND CERTIFICATION NON FORUM SHOPPING

I, Ronald, of legal age, Filipino and a resident Barangay Lawaan II, Talisay
City, Cebu subscribing under oath, hereby deposes and states that:
1. I am the complainant in the instant case;
2. I have read foregoing Complaint and the allegations therein are true and
correct of my own knowledge and/or based on authentic records on
hand;
3. I have not commenced any other action or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or different
Divisions thereof, or any other tribunal or agency;
4. No such action or proceeding is pending in the Supreme Court, the Court
of Appeals, or different Divisions thereof, or any other tribunal or
agency;
5. If I should learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or different
Divisions thereof, or any other tribunal or agency, I hereby undertake to
notify this Honorable Court within five (5) days from such notice.
WITNESS MY HAND this 25th day of February 2014 at Talisay City, Cebu,
Philippines.
Ronald
Affiant
In witness thereof, I, Mr. Gregorio D. Baldove III, counsel of the plaintiff,
have hereunto set my hand this 25th of February at Talisay City, Cebu.

Atty. Gregorio D. Baldove III

Counsel for the Plaintiff
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Block 7 Lot 67 Deca Homes 4
Bankal, Lapulapu City, Cebu, Philippines