Professional Documents
Culture Documents
Collection for
Sum of Money with
-Versus- Damages
Defendants
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COMPLAINT
even left words of assurance that she will return all the goodness
done to her when time comes that she will also be of help to
Plaintiff’s family;
11. True enough Defendant Dr. was able to pass the medical board
Page four
Complaint
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14. Plaintiff sought for legal advice from Atty. Sudayon and the
undersigned. The parties are both close friends; hence, they
initially tried to settle the issue by scheduling a pre litigation
conference between and among them on October 31, 2014 at the
office of the undersigned;
15. The said conference was attended by the parties including the
wife of the Plaintiff, and the father of the Defendants. There, an
agreement of both parties has been arrived at that the Defendants
will be going to pay the total amount of Four Hundred Twenty
Thousand Pesos (Php 420,000.00) within one (1) year from said
date on installment basis. The affidavit of Atty. Sudayon who
facilitated the pre litigation conference shall be submitted before
this Honorable Court to prove the veracity of this allegation, during
the trial proceedings of this case;
Page five
Complaint
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19. With the ultimate intention not to bring the instant case before
this Honorable and to have the same settled, the undersigned sent
another demand letter to remind the Defendants of their agreement
last October 31, 2014 but in a letter dated March 18, 2015,
Defendants totally denied their obligation and manifested their
desire to controvert the Plaintiff’s claim in the proper forum. A
copies of the letters are hereto attached and marked as Annexes
“E” and series and “F” and series respectively;
20. Demands indeed were made for the payment of the said loan
but the same fell into the deaf ears of the Defendants. They
refused and still refuse to pay the indebtedness to the prejudice of
herein Plaintiff;
PRAYER
WHEREFORE, WITH ALL THE FOREGOING, it is respectfully prayed this
Honorable Court that judgment be rendered in favor of herein Plaintiff and
against the Defendants and to:
Sudayon, Rhina
Counsel for Plaintiff