Republic of the Philippines
Second Judicial Region
REGIONAL TRIAL COURT
Branch 36
Santiago City
JESSICA PEKPEK
Plaintiff,
-versus-
Civil Case No. 2000-5637
(Collection of Payment)
ALEX NAVARRO,
Defendant.
x---------------------------------------x
COMPLAINT
Jessica Pekpek, plaintiff, thru counsel, and unto this Honorable Court,
respectfully alleges:
1. The plaintiff, Jessica Pekpek, and the Defendant, Alex Navarro, are
both of age and residents of Villasis, Santiago City;
2. On March 11, 2011, Alex Navarro obtained a loan from Jessica
Pekpek in the sum of EIGHT HUNDRED THOUSAND PESOS (Php
800,000.00) to be paid one year after date or March 12, 2012;
3. Said loan, now overdue, is evidenced by a written agreement signed
both by the plaintiff and defendant, a copy of which is hereto attached
as an annex A and made and integral part of this complaint;
4. On or about March 2012, Jessica Pekpek verbally demanded from
Alex Navarro the payment of such loan but the later did not pay and
promised to pay the same on the first week of August 2012;
5. On or about the first week of August 2012, Jessica Pekpek again
verbally demanded from Alex Navarro the payment of money but the
latter, once again, did not pay and instead promised to pay on the third
week of September 2012.
6. Several visits and demands, thereafter, were made by Jessica Pekpek
to Alex Navarro but they all produced no effect and the later still
failed to pay.
7. On or about December 10, 2013, as a last ditch effort, Jessica Pekpek
sent a demand letter in which Alex Navarro must pay the loan and
accrued interests from March 11, 2012, the date the loan was due and
verbally demanded, but the same was not heeded and the loan was
still unpaid. A copy of which is hereto attached as annex B.
WHEREFORE, it is respectfully prayed that:
1. Judgment be rendered against Alex Navarro in favor of Jessica Pekpek
for the sum of EIGHT HUNDRED THOUSAND PESOS (Php
800,000.00) with legal interest of 12% until the full amount is paid;
2. Alex Navarro be made to pay the costs of suit.
Santiago City, 4th day of September 2015.
JESSICA PEKPEK
Complainant
VERIFICATIONWITHCERTIFICATIONOF
NONFORUMSHOPPING
I, JESSICA PEKPEK, of legal age, Filipino, married and
residents of P6, Villasis, Santiago City, after having been duly sworn to an
oath in accordance with law, hereby depose and state the following, to wit:
1. That I have caused the preparation of the foregoing complaint ;
2. That I have read and understood the contents thereof, which are
true and correct of my personal knowledge, based on authentic
documents;
3. That I have not commenced any other action or proceeding
involving the same issues raised in time above captioned case in
the Supreme court, Court of Appeals or different division thereof
or any other court, tribunal or agency and to the best of my
knowledge, no such action or claim is pending thereof;
4. That should I come to learn that the same or similar action or claim
as been filed or pending before the Supreme court, Court of
Appeals or different division thereof or any other court, tribunal or
agency, I hereby undertake to notify this Honorable Court of such
fact within five (5) days from receipt of such knowledge;
4th day of September, 2015 at Santiago City.
JESSICA PEKPEK
Complainant
TH
SUBSCRIBED AND SWORN to before me in the City of Santiago
day of September 2015.
ATTY. JUNE RUDINI L. TOMAS
Notary Public
Santiago City and Isabela
Until Dec. 31, 2015/Notary Comm. No. 0091
Phil. BarRollNO.971462
PTRNO.A783452, Jan.17, 14, Isabela Chapter
IBPNO. 645906, Jan. 28, 14, Isabela Chapter
MCLEComplianceCert.No.12345, June 27, 2014
GonzalezBuilding, Maharlika Highway,
Centro East, Santiago City
Telephone Number-07-682 187
Doc No.
067
Page No.
04
Book No.
012
Series of 2015
March 11, 2011
I, Alex Navarro, resident of P7 Villasis, Santiago City, received from
Jessica Pekpek a sum of EIGHT THOUSAND PESOS (Php 800,000.00) as
a loan. Such loan shall be paid in lumpsum on March 11, 2012.
Jessica Pekpek
Creditor
Witnesses:
Arnold Clavencio
Kagawad
Karen Davil
Kagawad
Alex Navarro
Debtor
10 December 2013
ALEX NAVAROO
P7 Villasis, Santiago City
Sir:
This letter isin behalf of my client, Ms. Jessica Pekpek, the matter of your nonpayment of your obligation.
Records disclose that you have an outstanding obligation with our client in the
amount of Php800,000.00 exclusive of interest. Despite repeated demands, you
failed and continuously fail to pay the aforesaid amount.
Accordingly, FINAL DEMAND is hereby made upon you to settle the amount
ofPhp800,000 within FIFTEEN (15) days from receipt of this letter. Otherwise,
we will be constrained to file the necessary legal action against you to protect the
interest of my client.
I trust that you will give this matter your prompt and preferential attention to avoid
the expense and inconvenience of litigation.
Truly yours,
ATTY. JUNE RUDINI L. TOMAS
