Submitted By: Eloisa C.
Palmones
REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT Branch _____, Manila City DELOS REYES, EDDIE, Plaintiff, -versusCivil Case No. ________ FOR: SUM OF MONEY
DELA CRUZ, JUAN, Defendant. X----------------------------------------------X COMPLAINT PLAINTIFF by counsel, unto the Honorable Court, most respectfully avers that: 1. Plaintiff is of legal age, Filipino, single and resident 17 Hernaez Street,
Manila City; 2. Defendant is of legal age, Filipino, single, resident of Lot 4, Block 6,
Phase I, Mahogany Place, Taguig City, where he may be served with summons and other judicial processes; 3. That on October 20, 2009, defendant executed a promissory note in favor
of the plaintiff in the amount of P150,000.00 payable within three months from the date of the promissory note (attached as Annex A) ; 4. That defendant issued on January 25, 2010 BDO check no. 12345 in the
amount of P73,326.00 as payment of his balance; 5. funds; 6. That the three month period had elapsed and despite demands made orally That the said check was dishonored by the drawee bank due to insufficient
and in writing (attached as Annex B) by the plaintiff, defendant refused and failed to pay the amount stated in the promissory note.
7.
That due to the unjust refusal of defendant to comply with the demands,
plaintiff was compelled to file the instant action engaging the services of counsel in the amount of P10,000.00.
PRAYER WHEREFORE, plaintiff respectfully prays for judgment in her favor through a Decision directing defendant to pay him SEVENTY THREE THOUSAND and THREE HUNDRED TWENTY SIX PESOS (P73,326.00), with legal interest, as ACTUAL DAMAGES and TEN THOUSAND PESOS (P10,000.00) as Attorneys Fees.
Other just and equitable reliefs are also prayed for. Manila, July 25, 2011. ATTY. CESARIO JIMENEZ Counsel for the Plaintiff SAMSON AND SANTOS LAW OFFICE Unit 501, 1234 Rizal Avenue, Sta. Cruz, Manila City, 1100 IBP OR. NO. 563252 January 06, 2011, Manila City PTR NO. 563352 January 6, 2011, Manila City
VERIFICATION AND CERTIFICATION
I, EDDIE DELOS REYES, of legal age, single, Filipino, and resident of 17 Hernaez Street, Manila City, after having been sworn to in accordance with law, do hereby depose and say that:
1. I am plaintiff in the instant case; 2. I have caused the preparation of the Complaint, and I have read the contents thereof and the same are true and correct to the best of my personal knowledge and beliefs;
3. The documents attached therein are authentic and are faithful reproduction of the original; 4. I hereby certify that I have not filed similar action or complaint involving the same parties and cause of action; that there is no pending case between the same parties or cause of action before any court or tribunal, but should I learn that there is such action, I will undertake to inform the Honorable Court of such pendency, within five (5) days from knowledge.
IN WITNESS WHEREOF, I hereby affixed my signature this 25th day of July 2011, in Manila City, Philippines.
Eddie Delos Reyes Affiant CTC No. 1234567891 Issued on June 2, 2011 Issued at Manila City
SUBSCRIBED AND SWORN TO BEFORE ME, this 25th day of July 2011, in the City of Manila, Philippines, affiant exhibiting to me his CTC No.12345691 issued on June 2, 2011 issued at Manila City.
ATTY. CESARIO JIMENEZ Counsel for the Plaintiff SAMSON AND SANTOS LAW OFFICE Unit 501, 1234 Rizal Avenue, Sta. Cruz, Manila City, 1100 IBP OR. NO. 563252 January 06, 2011, Manila City PTR NO. 563352 January 6, 2011, Manila City Doc. No.1 Page No.3 Book No. 4 Series of. 2011
