REPUBLIC OF THE PHILIPPINES

Third Judicial Region

MUNICIPAL TRIAL COURT OF PLARIDEL
BRANCH 8
LPM MARKETING INC.
Plaintiff,
vs.
FRANCIS B. MARQUEZ,
Lisa B. Marquez
Defendants
x----------------------------x

CIVIL CASE NO. 15-1244

FOR SUM OF MONEY

COMPLAINT
COMES NOW, the plaintiff, through the undersigned counsel,
and unto this Honorable Court, respectfully avers:
1. The Plaintiff LPM MARKETING represented by Juliana
Cheong, is of legal age, Filipino and with business
address at 2nd Floor, Rocka Commercial Complex,
Cagayan Valley Road, tabang Plaridel, Bulacan, where
she can served with summons and other processes of
the Honorable Court. A copy of the Secretary Certificate
is hereto attached as Annex A
2. That defendant Francis B. Marquez and Lisa B. Marquez
owners of LPM MARKETING INC. of legal ages, Filipinos
and doing business at Cupang, Pandi, Bulacan, where
they can be served summons and other processes of
the Honorable Court.
FACTS OF THE CASE
a) That on several occasions in 2013, defendants herein
bought farm products to plaintiff herein in CREDIT for
their Wonderful Feeds in the amount of ONE
HUNDRED EIGHTY THREE THOUSAND NINE HUNDRED
FORTY THREE AND 50/100 (p183,943.50). A copy of
Statement of Account is hereto attached as Annex
B.
b) That defendants never pay as they promise and even
the principal amount, hence they are now in default.
c) That several personal, phone calls, text messages
and written demand were made by the Plaintiff
herein but Defendants refused and failed to pay the
said amount. A copy of demand letter wit return card
are hereto attached as Annex C and C-1.
d) That Plaintiff hired the services of counsel for the
enlightenment of the case and paid the amount of
TWENTY THOUSAND PESOS (20,000.00) AND TWO
THOUSAND PESOS (P2,000.00) per appearance.

PRAYER
WHEREFORE, it is most respectfully prayed to the
Honorable court, after due notice and hearing that
Judgment be rendered in favour of the plaintiff and
ordering the defendants:
1. Ordering the defendants to pay the amount of ONE
HUNDRED EIGHTY THREE THOUSAND NINE
HUNDRED FORTY THREE AND 50/100 (183,943.50)
with legal interest from judgment.
2. Ordering the defendants to pay the Attorneys
Fees in the amount of TWENTY THOUSAND PESOS
(P20,000.00) and TWO THOUSAND PESOS
(P2,000.00) per appearance.
3. Other relief are likewise prayed for.

Atty. Kimberly B. Milag

Roll of Attorney No. 96389
PTR. No. 4755945/01.13.15/Makati
City
IBP No.0984727/01.07.15/Manila II
MCLE Compliance No. IV007139/08.02.12

CERTIFICATION/ VERIFICATION
I, JULIANA CHEONG of legal age, Filipino and with business
address at 2nd Floor Rocka Commercial Complex, Barangay
Tabang, Plaridel Bulacan after having been sworn in accordance
with law do hereby deposed and say:
1. That I am the duly authorized representative of the plaintiff
in the above-entitled case;
2. That I have caused the preparation of the foregoing
complaint;
3. That I have read and understood the allegations contained
herein;
4. That the allegations therein are true and correct to the best
of my knowledge and belief,
5. That I have not commence any other action or proceeding
involving the same issue in the Supreme Court, Court of
Appeals or any other Tribunal.
6. That to the best of my knowledge, no other proceeding or
pending in Supreme court, Court of Appeals or any other
Tribunal;
7. That if after the filing of this complaint, I learned that a
similar action or proceeding has been filed or is pending
before any other tribunal or agency, I undertake to report the

fact within Five (5) days there from to the Court of Agency
wherein the original pleading therein have been filed.
_______________________
Affiant
ID SSS 333-3075345-9
SUBSCRIBED AND SWORN before me this 30th of July 2015 at
Malolos City, Bulacan.
Doc No. 398
Page No.80
Book No. 11
Seeries of 2015

REPUBLIC OF THE PHILIPPINES

PLARIDEL, BULACAN ) S.S.
SECRETARY CERTIFICATE
KNOW ALL MEN BY THESE PRESENTS
I, Tonya C. Chavez of legal age, Filipino citizen, with office address
at Unit 12th floor Rocka Commercial Complex Tabang, Plaridel,
Bulacan, do hereby depose and state.
1. That I am the duly elected and incumbent Corporate
Secretary of LPM Marketing Inc., a corporation duly
organized and existing in accordance with Philippine laws
with principal office at Unit 12th floor Rocka Commercial
Complex Tabang, Plaridel, Bulacan.
2. That at a meeting held on April 25, 2013 at which a quorum
was present, the following resolution was unanimously
adopted and approved.
RESOLVED, that Juliana Cheong of LPM Marketing Inc.,
whose signature affixed below is hereby named constituted
and appointed to be the representative of the corporation to
file Civil/Criminal before Municipal Trial Court against Francis
B. Marquez/Wonderful Feeds.
Name
JULIANA CHEONG
SSS ID # 333-3075345-9

SIGNATURE
__________________
(Specimen Signature)

TONYA C. CHAVEZ
SSS ID # 33-8713829-9
CORPORATE SECRETARY
IN WITNESS WHEREOF, I have hereunto affixed my signature this
30th day of july at Plaridel Bulacan, Philippines.
Doc No 310
Page No. 103
Book No. XII
Series# 2013