Republic of the Philippines

6TH JUDICIAL REGION

Regional Trial Court
Branch _____
Iloilo City

MIA C. SANCHEZ, Civil Case No. _____________

Plaintiff FOR: COLLECTION FOR A
SUM OF MONEY WITH
DAMAGES
- versus -

PAOLO D. CRUZ,
Defendant
x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court,

hereby respectfully avers:

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

Alta Tierra Village, Jaro, Iloilo City, Philippines
2. Defendant is also of legal age, married, Filipino and a resident of
Brgy. Dungon A., Jaro, Iloilo City, Philippines where summons
and court processes may be served;
3. That on February 14, 2013, the defendant borrowed from the
plaintiff a sum of money amounting to One Million Pesos
(PhP1,000,000.00) with an agreed interest of five percent (5%) per
month as evidenced by a promissory note herein
4. That as shown in the attached promissory note, the indebtedness of
the defendant has become due and demandable on February 14,
2014;
5. That despite plaintiff's repeated demands, both written and verbal,
defendant failed, neglected and refused to fulfill obligations
without just and valid grounds to the continued damage and
prejudice of plaintiff, as evidenced by Annex “A” – Demand
Letter;

6. That before resorting to legal action, plaintiff and defendant

resorted to Barangay Conciliation which likewise failed. Hence
attaches as Annex “B” – Certificate To File Action is issued to
parties to direct the matter to the court
 7. Plaintiff has resorted to legal action against the defendant sought
the services of a legal counsel with attorney’s fees amounting to
One Hundred Thousand Pesos (PhP 100,000.00) and an appearance
fee of Two Thousand Pesos (PhP 2,000.00) per hearing as
evidenced by Annex “C” – Contract for Legal Services;

8. That the plaintiff has suffered moral damages at the sum discretion
of the Honorable Court;

WHEREFORE, premises considered, it is hereby respectfully prayed

before the Honorable Court to render decision in favor of the plaintiff and
order the defendant to pay the following:

a. the sum of One Million Pesos (PhP 1,000,000.00) plus interest at

the rate of five percent (5%) per month as stipulated in the
promissory note;

b. moral damages, exemplary damages at the sum discretion of the

court;

c. attorney’s fees amounting to One Hundred Thousand Pesos (PhP

100,000.00) and an appearance fee of Two Thousand Pesos (PhP
2,000.00) per hearing

d. litigation expenses amounting to Twenty Thousand Pesos (PhP

20,000.00).

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

Iloilo City, December 6, 2014.

ATTY. VINCENT ENRIQUE A. VARONA

Counsel for Petitioner
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876, 01/02/14
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF ILOILO ) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, MIA C. SANCHEZ, of legal age, Filipino, married, and a resident

of Alta Tierra Village, Jaro, Iloilo City, Philippines, after being sworn in
accordance with law, hereby depose and say:

(1) That I am the Plaintiff in the above-entitled case;

(2) That I have caused the preparation of the above Complaint and I
have read the same and understood the contents thereof;

(3) That the allegations contained therein are true and correct of my
own personal knowledge and based on authentic records.

(4) That I further certify that: I have not theretofore commenced any
other action or proceeding or filed any claim involving the same issues or
matter in any court, tribunal, or quasi-judicial agency and, to the best of my
knowledge, no such action or proceeding is pending therein; if I should
thereafter learn that the same or similar action or proceeding has been filed or
is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5)
days therefrom to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 6th day

of December 2014 at Iloilo City, Philippines.

MIA C. SANCHEZ
Affiant
TIN 98765-003; Iloilo City
 SUBSCRIBED AND SWORN to before me, this 6th day of
December 2014, affiant exhibiting to me his Tax Identification Card as
shown above below his name as competent evidence of his identity.

ATTY. VINCENT ENRIQUE A. VARONA

My Commission No. is 58
Expires on December 31, 2015
Varona Law Office, Alta Tierra Village, Jaro, Iloilo City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/14, Iloilo City
IBP NO. 123456, 01/04/14, Iloilo City
MCLE Comp. No. IV-0009876, 01/02/14

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2014;