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COMPLAINT
1. I, Juan Dela Cruz, Filipino, of legal age, single, and a resident of No. 5
Happy Homes, Tabaco City, Philippines, after being sworn to in
accordance with law, depose and state:
2. That I know the person of Maria Clara, who is a resident of 234 Vel
Amor Subdivision, Legazpi City, Philippines, where she may be served
with summons;
5. That at the time said Maria Clara issued and delivered the promissory
note to me, she made the assurance and representation that the
amount due will be paid by her 1 (one) year after issuance thereof.
Attached herewith, to form an integral part hereof, is a copy of the
said promissory issued by the defendant, as Annex "A.
6. However, after the lapse of 1 (one) year, the time when the loan was
then due and demandable, the defendant failed to settle her
obligation, despite repeated oral demands;
7. As such, written demand for the payment of the amount due was sent
to her, but the defendant still failed to settle her obligation. Attached
herewith, to form an integral part hereof, is a copy of the said demand
letter issued by me for the defendant, as Annex "B.
8. That due to the noncompliance of the defendant with the said
demands, the plaintiff was then compelled to institute this action
engaging the services of a counsel in the amount of Php 5,000.00.
PRAYER
Other reliefs just and equitable under the premises are likewise prayed for.
JENNINE R. ORIBIANA
NOTARY PUBLIC
UNTIL DEC. 21, 2015
COMMISSION NO. 20
PTR . NO. 277277 JAN. 5, 2015
IBP NO. 98769876 JAN. 5, 2015
ATTY. ROLL NO. 977277
PVLB BLDG, LORENZO ST.
TABACO CITY