REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT OF MANILA
6TH JUDICIAL REGION
BRANCH 16
MANILA
ALEXANDER D. GREATEST,
Plaintiff.
CIVIL CASE NO. ____
---versus --- For: Collection of Sum
of Money
JUAN P. MASIPAG
Defendant.
x---------------------------------x
COMPLAINT
Plaintiff, thru the undersigned counsel, and unto this Honorable Court,
respectfully avers the following:
1. That plaintiff, Alexander D. greatest is a resident of No. 112
Liberty Street, Mandaluyong City; while defendant, Juan P.
Masipag is a resident of No. 2, Juan de la Cruz Street, Sampaloc,
Manila, where they may be served with summons;
2. Than on January 13, 2007, defendant Masipag borrowed from the
plaintiff the sum of ONE MILLION PESOS (Php 1,000,000.00)
with interest at the rate of TWELVE (12%) percent per annum and
in case of non-payment at maturity as evidenced by a promissory
note executed on January 13, 2007, hereto attached as Annex A
and made an integral part hereof by refence;
3. That of said principal obligation which became due and
demandable on January 14, 2009, defendant has not made any
payment, the total amount due on the loan account is ONE
MILLION NINE HUNDRED SIXTY THOUSAND PESOS (Php
1,960,000.00), including interests;
4. That defendants have failed and refused, and still fail and refuse to
pay the same or any part thereof, notwithstanding the repeated and
final demands from plaintiff, herein attached as Annexes B, C
and D and made integral parts hereof;
5. That by reason of unjustified refusal to satisfy plaintiffs plainly
valid, just and demandable claim, the latter was compelled to
engage the services of counsel and incur litigation expenses in the
sum of SEVENTY-FIVE THOUSAND PESOS (Php 75,000.00)
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attorneys fees, and a fee of THREE THOUSAND PESOS P
3,000.00. for every appearance in court;
WHEREFORE, in view of the foregoing, plaintiff respectfully prays
to this Honorable Court, that after due hearing, judgment be rendered in
favor of the plaintiff and against the defendants:
1. That they be ordered to pay the plaintiff the sum of ONE
MILLION NINE HUNDRED SIXTY THOUSANDPESOS ONLY
(Php 1,960,000.00), which includes the principal amount and
interests from January 3, 2008 computed as agreed upon by the
partiesin the promissory note;
2. That they be ordered to pay all the legal fees including attorneys
fees and appearance fee for every hearing in court.
Plaintiff further prays for such other relief as the Honorable Court
may deem just and equitable in the premises.
Iloilo City, May 10, 2017.
NONITO Q. PASUELO, JR.
Counsel for Plaintiff
Suite 007, 2nd Floor, Pasuelo Tower
MEGAWORLD, Iloilo City
Roll No. 66199
IBP No. 011 Lifetime
PTR No. 70 - 1/2/16 Iloilo
MCLE Compliance IV No. 001234
Issued on January 12, 2015
VERIFICATION AND CERTIFICATION
I, ALEXANDER D. GREATEST of legal age residing at No. 112
Liberty Street, Tondo, Manila, after being sworn to in accordance with law,
deposes and says that:
1. I am the Plaintiff in the above-titled case;
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2. The facts stated in the above complaint are true and correct to the
best of my knowledge and authentic records;
3. I have 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 other action or claim is pending
in them; and
4. If I should learn that the same or similar action or claim has been
filed or is pending after its filing, I shall report that fact within five
(5) days from notice to the court or where the complaint or
initiatory pleading has been filed.
Signed this 8th of May, 2017, in Iloilo City, Philippines.
ALEXANDER D. GREATEST
Affiant
SUBSCRIBED and sworn to before me, this _10th_ day of January,
2017, in the City of Iloilo with SSS No. 07-2157659-3 issued on June 16,
2000 in Iloilo City, Philippines. I hereby certify that I have examined the
affiant.
ROXAN R. LABIS
Counsel for the Plaintiff
Roll of Attorney 108831
IBP No. 857218, 01/03/16, Iloilo City
PTR No. 1316719, 01/03/16, Iloilo City
MCLE COMP. NO. IV-0005397, 03/03/16
Doc. No. _______;
Page No. _______;
Book No. _______;
Series of 20 _____.
ANNEX A
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ANNEXB
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ANNEXC
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ANNEXD
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