REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Manila, Branch 1

CONRAD PASCUAL,
Plaintiff
- versus- Civil Case No.__________
For: Collection of Sum of Money,
CHRISTOPHER PASCUAL, Attorneys Fees and Other Reliefs
Defendant.
x-----------------------------------------x
COMPLAINT

COMES NOW Plaintiff, by counsel, unto this Honorable Court, most

respectfully states:

1. That plaintiff is of legal age, married, Filipino and a resident of #111

Libertad St., Sampaloc, Manila. He may be served with notices,
orders and processes of this Honorable Court through undersigned
counsel.

2. That defendant is likewise of legal age, Filipino and a resident of #

222 Juan Luna St., Tondo Manila, where he could be served with
summons and other processes of the Court.

3. That the plaintiff and defendant are related to each other as brothers.

4. That sometime on 03 January 3, 2016, in the city of Manila, for

valued received, the defendant Christoper Pascual executed a
promissory note in favor of the plaintiff Conrad Pascual in the sum of
One Million Pesos (Php 1,000,000.00), with 12% interest per annum,
to be fully paid within one date from the date of note.

5. That a copy of the said promissory note is hereto attached as

ANNEX A

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 6. That despite the lapse of period, defendant Christopher Pascual failed
to pay, despite repeated demands, the principal amount of One Million
Pesos (P1,000.000.00), on or Before January 3, 2017 plus an interest
rate of 12% per annum and therefore plaintiff, through his counsel,
sent a demand letter to defendant demanding him to pay
aforementioned principal amount of One Million Pesos (P1,000,000)
plus a more or less One hundred Forty Thousand (P140,000.00)
representing the total interest from January 3, 2016 up to the filing of
this complaint.

7. That a copy of the aforementioned demand letter is hereto attached as

ANNEX B.

8. That all other subsequent demands made by the plaintiff were all met
by adamant refusal by defendant.

PRAYER
WHEREFORE, after hearing and trial, judgment is rendered in
favor of plaintiff and against defendant, ordering the latter as follows:

1. To pay plaintiff the amount of One Million Pesos (P1,000,000.00)

plus One Hundred Forty Thousand Pesos (P140,000.00)
representing the total interest from January 3, 2016 up to February
28, 2017 and further interest until the amount is fully paid.

2. Attorneys fees equivalent to Ten percent (10%) of the principal

amount.

3. Costs of Litigation

4. Other just and equitable relief.

City of Makati, 24 February 2017

Atty. Romela M. Eleria
Counsel for Plaintiff
#6751 Office Tower Ayala Avenue
17th floor Makati, Philippines.
PTR No. 1473621, 01-08-2017

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 IBP OR NO. 123041,01-08-2017
Roll No. 489023

REPUBLIC OF THE PHILIPPINES )

CITY OF MANILA ) S.S.
x----------------------------------------------------x

VERIFICATION AND CERTIFICATE

I, CONRAD PASCUAL, of legal age, married, Filipino and a

resident of #111 Libertad St., Sampaloc, Manila, after having sworn to in
accordance with law, hereby depose and state.

1. That I am the Plaintiff in the above-entitled case.

2. That I caused the preparation of this complaint, and have read it; and
the contents thereof are true and correct of my personal knowledge
and as based on the records on hand.

3. That I further certify that I have not commenced any action or filed
any claim involving the same issued in any court, tribunal or quasi-
judicial agency, and there is no other action or claim pending therein;
that if there is any such pending action or claim or similar action or

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 claim is pending, I shall immediately report that fact to this Honorable
Court, within five (5) days from knowledge thereof.

IN WITNESS THEREOF, I hereunto affix my signature this 24

February 2017, City of Makati, Philippines.

Conrad Pascual
Affiant

SUBSCRIBED AND SWORN TO before me this 24th day of February

2017, at City of Makati, Philippines, affiant exhibiting to me his Driver
License No. 045463164525 issued in City of Manila on 08 December 2015.

Atty. Romela M. Eleria

Counsel for Plaintiff
#6751 Office Tower Ayala Avenue
17th floor Makati, Philippines.
PTR No. 1473621, 01-08-2017
IBP OR NO. 123041,01-08-2017
Roll No. 489023