Republic of the Philippines
REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
QUEZON CITY
BRANCH 31
NICOLE DOMINIQUE N. IBAY,
Plaintiff,
vs CIVIL CASE NO. 6171995
Collection of Sum of Money
SELENA GOMEZ,
Defendant.
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COMPLAINT
PLAINTIFF NICOLE DOMINIQUE N. IBAY, by counsel, to this
Honorable Court, respectfully states that:
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1. Plaintiff, Nicole Dominique N. Ibay, 24 years old, Filipino, single,
residing at #78 B Gen. Segundo St. heroes Hill, Quezon City
2. Defendant, Selena Gomez, 24 years old, Filipino, single, residing at
tower 3 Unit b The good place, Quezon City, where they may be served
with summons and other processes of this Honorable Court;
3. That on October 1, 2016 defendant borrowed from the plaintiff a sum
of money amounting to Five Hundred Thousand Pesos
(PhP500,000.00) with an agreed interest of twelve percent (12%) per
annum as evidenced by a promissory note dated October 15, 2016
herein attached as Annex “A” and form an integral part of this
complaint;
4. That as shown in the attached promissory note, the indebtedness of
the defendant has become due and demandable on October 15, 2017;
5. That plaintiff writes a demand letter giving fifteen (15) days for
defendant to comply with his obligation. Demand letter herein attached
as Annex “B” and form an integral part of this complaint;
6. 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;
7. That the plaintiff in order to enforce his rights and interests, has
sought the services of a legal counsel with attorney’s fees amounting
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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 paid for litigation expenses amounting to
Twenty Thousand Pesos (PhP 20,000.00) as evidenced by Annex “D”
– Official Receipt;
9. 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 Five Hundred Thousand Pesos (P 500,000.00)
plus interest at the rate of twelve percent (12%) per annual 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;
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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.
Quezon City, November 7, 2019
ATTY. HARRY EDWARD STYLES
Counsel for Petitioner
Styles-Malik Law Office – Quezon City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/17, Quezon City
IBP NO. 123456, 01/04/17, Quezon City
MCLE Comp. No. IV-0009876, 12/31/19
VERIFICATION/CERTIFICATION
I, Nicole Dominique N. Ibay, 24 years old, Filipino, single and
resident of #78B Gen. Segundo St, Heroes Hill, Quezon City, after
having been sworn in accordance with law, hereby depose and state:
1. That I am the complainant in the above-entitled case;
2. That I have caused the preparation of the foregoing Complaint;
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3. That I have read and understood all the allegations contained
therein, and the same is true and correct of my own personal
knowledge and based on authentic records;
4. That I certify under oath that I have not commenced any other
action or proceeding which is pending in the Supreme Court, the Court
of Appeals, or any other tribunal or agency. To the best of my
knowledge, no such action or proceeding is pending in the Supreme
Court, the Court of Appeals, or any other tribunal or agency;
5. I likewise undertake that if there is any such action or proceeding
which is either pending or may have been terminated, I will state the
status thereof. If I should thereafter learn that the similar action or
proceedings has been filed or is pending before the Supreme Court,
the Court of Appeals, or any other tribunal or agency. I will undertake
to report the fact within five days therefrom to the Court or agency
wherein the original pleadings an sworn certification contemplated in
Administrative Circular No. 04-94 February 8, 1994.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
11th day of November 2019, in Quezon City, Philippines.
Affiant
Driver’s License No. AO1-98-065487
Expiry Date: 2020-01-17
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SSS ID No. 33-44556677
SUBSCRIBED AND SWORN TO BEFORE ME, a Notary Public
for and in Quezon City, affiant personally appeared having exhibited to
me her Social Security System Identification Card which details are
indicated below her name and signature.
WITNESS MY HAND AND SEAL this 11th day of November 2019
in Quezon City.
ATTY. LIAM PAYNE
NOTARY PUBLIC
Roll of Attorneys No. 543213
PTR NO. 12345, 04/06/17, Quezon City
IBP NO. 23456, 04/04/17, Quezon City
MCLE Comp. No. IV-0009435, 31/12/19
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2019
