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KRIS E. QUINO,
Plaintiff,
11.
By reason of defendants unreasonable failure or refusal
to pay his due and demandable obligation, plaintiff was forced
to engage the services of counsel to vindicate his rights thereby
committing herself to pay legal expenses amounting to Thirty
Thousand Pesos (P30,000.00);
12.
That as a result of the unjustified and unwarranted refusal
of the defendant to pay the plaintiff the said amount and
interest, he suffered sleepless nights, serious anxiety in which
she would be awarded the amount of P50,000.00 as moral
damages, and to set an example to the public, plaintiff should
be awarded exemplary damages in the amount of P50,000.00.
WHEREFORE, premises considered, it is most
respectfully prayed unto this Honorable Court that, after
hearing, judgment be rendered in her favour through a decision
directing defendant to pay him THREE HUNDRED THOUSAND
PESOS (P300,000.00), with legal interest, FIFTY THOUSAND
PESOS (P50,000.00) as MORAL DAMAGES, FIFTY
THOUSAND
PESOS
(P50,000.00)
as
EXEMPLARY
DAMAGES, and THIRTY THOUSAND PESOS (P30,000.00) as
Attorneys Fees.
Other just and equitable reliefs are also prayed for.
Iloilo City, Iloilo, March 20, 2015.