REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Quezon City, Branch

AOV Corporation,
Plaintiff,

-versus- Civil Case No. ______________

For: Collection of Sum of Money

MOB League Inc.,

Defendant,
x-----------------------------------------x

COMPLAINT

Plaintiff through counsel respectfully states that:

1. Plaintiff, as represented by its President Jalalin A. Macabangon is a

corporation duly registered under the Philippine laws, with principal office
address at ____________________________________,

2. Defendant is a corporation duly registered under the Philippine laws, with

principal office address at __________________________, where
summons as well as court papers may be served.

3. Plaintiff corporation is engaged in the sale of appliances, computer parts

and accessories. Defendant corporation is also engaged in the sale and
distribution of home appliances.

4. Sometime in 01 December 2016, Plaintiff and Defendant entered into a

Contract of Sale of home appliances, payable within thirty (30) days from
the date of last delivery.

Attached and made integral as part hereof as “Annex A” is the said

Contract of Sale.

5. On 30 March 2017, the Defendant Corporation received a total of one

hundred forty eight (148) home appliances with aggregate value of TWO
 MILLION THREE HUNDRED SEVENTY NINE THOUSAD AND SIX
HUNDRED FIFTY PESOS (P2,363,560.00) in a series of deliveries from
01 December 2016.

Attached and made integral as part hereof as “Annex A-1 to B-148” are
the 148 receipts of the items purchased.

6. On 30 April 2017, the Defendant corporation received a home appliance

valued at SIXTEEN THOUSAND NINETY PESOS (P16, 090.00).

Attached and made integral as part hereof as “Annex A-149” is the receipt
of the item purchased.

7. As to date of 30 April 2017, the Defendant Corporation have in their

possession of the one hundred forty-nine (149) home appliances with
aggregate value of TWO MILLION THREE HUNDRED SEVENTY-
NINE THOUSAND SIX HUNDRED FIFTY PESOS (P2,379,650.00).

8. On May 22, 2017, Defendant made a partial payment of ONE HUNDRED

FOUR THOUSAND TWO HUNDRED TWENTY-ONE PESOS AND
SEVEN CENTAVOS (P104,221.07).

9. On 04 June 2017, a written demand through its Legal Department Head

was sent to the Defendant Corporation, demanding payment of the balance
amounting to TWO MILLION TWO HUNDRED SEVENTY-FIVE
THOUSAND FOUR HUNDRED TWENTY-EIGHT PESOS AND
NINETY-THREE CENTAVOS (P2,275,428.93).

10.As of today, the Defendant has failed to pay the remaining balance
amounting to TWO MILLION TWO HUNDRED SEVENTY-FIVE
THOUSAND FOUR HUNDRED TWENTY-EIGHT PESOS AND
NINETY-THREE CENTAVOS (P2,275,428.93) despite demand.
Attached and made as integral part hereof as “Annex E” is a Statement of
Account of the total obligations.
 PRAYER

WHEREFORE, it is respectfully prayed that judgment be rendered

ordering Defendant:

a) To pay Plaintiff the sum of P2,275,428.93 as payment of the Defendant’s

existing obligation;

b) To pay Plaintiff the sum of P100,000.00 as attorney’s fee plus;

c) To pay Plaintiff the sum of P50,000.00 as litigation expenses and

P3,000.00 per court appearance of the Plaintiff’s counsel;

d) To pay the cost of suit.

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

Quezon City, June 06, 2017

Gerald Baluyot
Counsel for Plaintiff
Taft cor. Menlo St., Pasay City
PTR No. 1888888/1-25/ Pasay City
Roll of Attorneys No. 105699
IBP No. 105888/1-8-2019 Bataan
MCLE Exemption No. V-000188
April 10, 2019/ Pasig City

CERTIFICATION AND VERIFICATION

I, Jalalin A. Macabangon, of legal age, Filipino and holding office at Quezon

City, declares under oath that:
 1. I am corporate President of Plaintiff in the above entitled case; I caused the
preparation of the foregoing petition; and all material allegation therein are
true of my own knowledge;

2. Plaintiff has not commenced any action or filed any claim involving the
same issues in any court, tribunal or quasi-judicial agency and to the best of
my knowledge, no such action or claim is pending therein;

3. Should I hereafter learn that the same or similar action or claim has been
filed or is pending before any court, tribunal or quasi-judicial agency, I
undertake to report said fact within five (5) days from such knowledge to
this Honorable Court.

Jalalin A. Macabangon

Republic of the Philippines)

Quezon City )s.s

SUBSCRIBED AND SWORN to before me this ____ day of ________,

2019, affiant exhibiting to me his ID No. ___________, issued by _________.

Doc No. _______

Page No. ______
Book No. ______
Series of 2017