REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT NATIONAL NATIONAL CAPITAL JUDICIAL REGION RE GION Branch __, MANILA ALEXANDER SISON Plaintiff, Civil Ca! N"# _________ F"r& S%' "( M"n!)
$v!r%$ JUAN JAMERO Defendant. X$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$X
COMPLAINT
Plaintiff, through the undersigned counsel unto this Honorable Court, hereby respectfully states as follows: 1) Plaintiff, is of legal age, single, Filipino, and a resident of 111 Libertad t., a!paloc, "etro "anila, Philippines while the Defendant is also of legal age, single, Filipino, and a resident of ### $uan Luna t., %ondo, "etro "anila, Philippines where su!!ons and court proceedings !ay be ser&ed' #) %hat, the Defendant borrowed fro! the Plaintiff a su! of !oney a!ounting to (* "+LL+( pesos P1,---,---.--), with 1# interest per annu!, as e&idenced by a Pro!issory ote herein attached as /0nne 02 and for! an integral part of the co!plaint' 3) %hat %hat,, the the inde indebt bted edne ness ss of the the Defe Defend ndan antt has has beco beco!e !e due due and and de!a de!and ndab able le on $anu $anuar ary y 3, #--4 #--4,, a year year afte afterr it was was pro! pro!is ised ed in the the pro!issory note' 5) %hat, despite repeated &erbal and written de!ands !ade by the Plai Plaint ntif ifff upon upon the the Defe Defend ndan ant, t, the the Defe Defend ndan antt has has fail failed ed to fulf fulfil illl his his obligation as e&idenced by /0nne 62' 7) %hat, the Plaintiff in order to enforce his rights and interests, has soug sought ht the the ser& ser&ic icee of a lega legall coun counse sell with with atto attorn rney ey8s 8s fees fees a!ou a!ount ntin ing g P97,---.-- and an appearance fee of P3,---.-- for e&ery appearance in court as e&idenced by /0nne C2'
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*HEREFORE, pre!ises considered, it is hereby respectfully prayed before the Honorable Court to render decision in fa&or of the plaintiff and order the Defendant to pay the following'
a) u! of (ne "illion Pesos P1,---,---.--), plus interest at the rate of %wel&e Percent 1#) per annu! as stipulated upon in the Pro!isory ote' b) "oral da!ages, ee!plary da!ages, at the sound discretion of the court' c) 0ttorney8s fees a!ounting to P 97,---.-- plus 0ppearance Fee at the rate of P 3,---.-- per court hearingconference' d) Litigation epenses. (ther reliefs and re!edies dee!ed ;ust and e
RU++EL DIANE ODUCADO Counsel for the Plaintiff. CD* 6uilding >aleria t., +loilo City
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REPUBLIC OF THE PHILIPPINES CIT- OF MA.ATI SS# X$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$X /ERIFICATION AND CERTIFICATION
+, 0leander ison, Fillipino, of legal age, single and a resident of of 111 Libertad t., a!paloc, "etro "anila, Philippines, after duly being sworn to in accordance with law, hereby depose and say: %hat + a! the Petitioner of the abo&e?entitled case' %hat + ha&e caused the preparation of the abo&e Petition and + ha&e read the sa!e and =nows the contents thereof' %hat the allegations contained therein are true and correct of !y own personal =nowledge. %hat + further certify that: a) + ha&e not theretofore co!!enced any action or filed any action or clai! in&ol&ing the sa!e issue in any court, tribunal or
ALEXANDER SISON 0ffiant
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SUBSCRIBED AND S*ORN to before !e, this #7 th day of $anuary #--4 at "a=ati City, "etro "anila, Philippines, affiant ha&ing ehibited to !e his %+ bearing o. -1?5#@?#79?471 issued on $une 3, #--A at "etro "anila, Philippines.
ATT-# MA-REN P# ABUCION otary Public Bntil Dece!ber 31, #-1P% o. 1#357@9 +6P o. 7A@39 oll o. 1#357@
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