REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SEVENTH JUDICIAL REGION
BRANCH __
CEBU CITY

Mr. Lance Cruz

Plaintiff, Civil Case No. ____

for: Sum of Money
-versus-

Mr.Vin To,

Defendant.
x-----------------------------------------x

COMPLAINT

COMES NOW the plaintiff, by the undersigned counsel, unto

this Honorable Court, most respectfully states:

1. That the plaintiff is of legal age, married, a Filipino citizen and

a resident of Quiot, Pardo, Cebu, and that the defendant is likewise of
legal age, married, a Filipino citizen and a resident of Quezon
Highway, Marigondon, Lapu-lapu City, Cebu where he may be served
with summons and other court processes;

2. That on June 15, 2015, the defendant obtained a loan from

plaintiff in the sum of Five Hundred Thousand (P500,000.00) PESOS,
with the following terms and conditions:

a. The principal loan obligation shall be payable within one (1)

year from time of execution of agreement;

b. The principal loan obligation shall incur an interest of 12

percent per annum;

c. The loan was to mature on June 15, 2016.

3. That said loan, now overdue, is evidenced by a promissory

note signed by the defendant, a copy of which is hereto attached as
annex “A” and made part of this complaint;

4.That despite repeated demands, both written and oral,

defendant has failed and refused to pay said loan, a copy of the

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written demand is hereto attached as annex “B” and made part of this
complaint;

5. Due to the unjust and unlawful act of the defendant in failure

to comply with the said demands, the plaintiff was compelled to
institute this action engaging the services of the counsel in the
amount of Ten Thousand (P10,000.00) PESOS.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court that judgment be rendered against
defendant to pay the plaintiff the sum of Five Hundred Thousand
(P500,000.00) PESOS plus 12% interest from the date of the
instrument until the amount is paid and attorney’s fees in the amount
of Ten Thousand (P10,000.00) PESOS and costs of suit.

Such other reliefs and remedies under the premises are

likewise prayed for.

Cebu City, Philippines, this 3rd day of January 2017.

ATTORNEY KARISSA LOPEZ YEN

Counsel for the Plaintiff
PTR No. 933967, 1-04-17, Cebu City
IBP No. 37463, Lifetime, Cebu City
Roll of Attorney’s No. 42481, 4-15-14, Cebu City
MCLE Compliance V Certificate No. 98045, 3-24-16
7th Floor, Velvet Building, Pelaez Ext, Cebu City

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REPUBLIC OF THE PHILIPPINES )
CITY OF CEBU ) S.S.

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, LANCE CRUZ, of legal age, married, Filipino Citizen and a

resident of Quiot, Pardo, Cebu, after being sworn in accordance with
law, hereby depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein
are true and correct of my personal knowledge and on the basis of
copies of documents and records in my possession;

4. I have not commenced any other action or proceeding

involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding

has been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 3rdday of January, 2017 at the City of Cebu, Philippines.

Lance Cruz
Affiant

SUBSCRIBED AND SWORN TO before me this 3rd day of

January, 2017, in the City of Cebu by affiant exhibiting to me his
Professional Regulation Commission License No. 438767 issued on
August 24, 2016 in Cebu City.

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 ATTORNEY KARISSA LOPEZ YEN
Notary Public for and within the territorial
jurisdiction of the RTC of Cebu City, San
Fernando and Carcar City
Notarial Commission No. 2809
Until December 31, 2018
PTR No. 933967, 1-04-17, Cebu City
IBP No. 37463, Lifetime, Cebu City
Roll of Attorney’s No. 42481, 4-15-14, Cebu City
MCLE Compliance V Cert No. 91145, 3-24-16
7th Floor, Velvet Building, Pelaez Ext, Cebu City

Doc. No. 4;
Page No. 3;
Book No. 3;
Series of 2017.

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