REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

6th Judicial Region
Branch _______
Iloilo City
-000-

MAYA MAN, CIVIL CASE NO. _______

Plaintiff,

FOR: SPECIFIC PERFORMANCE

AND DAMAGES
-versus-

RICARDO DALISAY,
Defendant.
x--------------------------------------------------x

COMPLAINT

COMES NOW, plaintiff by the undersigned counsel unto this Honorable

Court most respectfully alleges:

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

Brgy. San Isidro, Jaro, Iloilo City, Philippines while the defendant is
also of legal age, married, Filipino and a resident of Brgy. Mali-ao,
Pavia, Iloilo, Philippines where summons and court processes may
be served;
2. That on January 01, 2018, the defendant borrowed from the
plaintiff a sum of money amounting to One Hundred Thousand
Pesos with an agreed interest of One percent (1%) per month as
evidenced by a Promissory Note herein attached as Annex “A” and
form an integral part of this complaint;
3. That as shown in the attached Promissory Note, the indebtedness
of the defendant has become due and demandable on June 30,
2018;
4. That despite plaintiffs repeated demands, both written and verbal,
defendant failed, neglected and refused to fulfill obligations without
just and valid grounds to the continued damaged and prejudiced of
plaintiff, as evidenced by Annex “B”- Demand Letter;
5. That the plaintiff in order to enforce his rights and interests, has
sought the services of a legal counsel with attorney’s fees
amounting to Thirty Thousand Pesos (Php30,000.00) and an
appearance fee of One Thousand Pesos per hearing.
 WHEREFORE, premise considered, plaintiff prays that upon due
hearing,judgment be rendered as follows:

a) That a sum of One Hundred Thousand Pesos (Php100,000.00)

plus interest rate of One percent (1%) 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 Thirty Thousand Pesos
(Php30,000.00) and an appearance fee of One Thousand
Pesos per hearing;
d) Litigation expenses amounting to Twenty Thousand Pesos
(Php20,000.00);

Plaintiff be granted such other relief in law and equity.

Iloilo City, Philippines, August 8, 2018.

JERE P. LEGARAY
PTR No. 6007195/Iloilo City/6/09/18
IBP No.005945/Iloilo City/05/19/18
Roll No. 67244
MCLE Exempt, passed the 2016 Bar Exams and
signed the Roll of Attorneys on 24 May 2017
Mobile Number: 09152087239
Email Add: legarayjere@gmail.com
REPUBLIC OF THE PHILIPPINES)
CITY OF ILOILO -------------------)S.S
x----------------------------------------x

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING

I, MAYA MAN, of legal age, Filipino, married, with residence address at

Brgy.San Isidro, Jaro, Iloilo, Philippines, after having been duly sworn to in
accordance with law, hereby depose and say:

1. That I am the plaintiff in the above -entitled case;

2. That I have read and have caused the preparation of the foregoing
COMPLAINT and that all the allegations contained therein are true and
correct to the best of my personal knowledge and/or based on
authentic records;

3. That I have not theretofore commenced any other action or

proceedings 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;

4. That if I should thereafter learn that a similar action or proceeding has

been filed or is pending in 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 ___ day of

_______________, 2018 in the City of Iloilo, Philippines.

MAYA MAN
Affiant

SUBSCRIBED AND SWORN to before me this ___ day

of_____________, 2018, in the City of Iloilo, Philippines. Affiant who personally
appeared with his I.D. No. _______________________by
_________________________ and known to me to be the same person to the
Notary Public or identified by the Notary Public through competent evidence of
identity as defined by the 2004 Rules on Notarial Practice pursuant to Supreme
Court EN BANC A.M. No. 02-8-13 SC Resolution. That the herein person
represented to the Notary Public that the signature on the instrument or
document was voluntarily affixed by him, and that the same is his free and
voluntary act and deed.

Doc. No. ______;

Page No. ______;
Book No. ______;
Series of 2018.