DEFENSOR & ASSOCIATES

Door 3, Therese Arcade, Bacolod City

Tel. No. 433-144/09215937965

July 8, 2011
MRS. LIZA C. PANTEROS
18 Rosario Heights, Brgy. Camingawan
Bacolod City
Mrs. Panteros:
The undersigned is writing you this correspondence in behalf of my client, Ms. Annie
B. Tucon, of No. 21 Alta Vista Subdivision, Brgy. Singcang, Bacolod City anent to the
money you borrowed from her last August 8, 2009 amounting to Six Hundred
Thousand Pesos (Php 600, 000.00) payable on or before August 8, 2010, of which
the promissory note you personally signed is hereto attached.
That after such credit become due and demandable, my client respectfully demand
payment from your part in many occasions to which you refuse to pay to this date.
Thereby, this is to warn you that if you fail to pay or contact my client or this office
until the end of this month regarding any payment or settlement, and to give any
reasonable explanation on the reason of your default, we will use the full force of
the law to oblige you in performing your obligation plus the damages incurred by
my clients from your avoidance.
Furthermore, let me remind you the expensive cost of litigation and the damages
which you will pay in case we already instituted an action against you which could
blemish as well your good standing in the business community.
Hence, we are humanely advising you to take immediate action and take this
opportunity to resolve this matter earnestly that you could avoid the severance of
the consequences due to you inaction.
Please be guided accordingly.

ATTY. NIEL S. DEFENSOR

Counsel for Ms. Annie B. Tucon
DEFENSOR & ASSOCIATES LAW OFFICE
Roll of Attorney No. ___________;
PTR No.______________;
IBP No.____________;

MCLE Compliance No. _______________;

DEFENSOR & ASSOCIATES

Door 3, Therese Arcade, Bacolod City

Tel. No. 433-144/09215937965

August 5, 2011
MRS. LIZA C. PANTEROS
18 Rosario Heights, Brgy. Camingawan
Bacolod City
Mrs. Panteros:
This is the second and last demand letter you will receive from this office. The
undersigned is writing you this correspondence in behalf of my client, Ms. Annie B.
Tucon, of No. 21 Alta Vista Subdivision, Brgy. Singcang, Bacolod City anent to the
money you borrowed from her last August 8, 2009 amounting to Six Hundred
Thousand Pesos (Php 600, 000.00) payable on or before August 8, 2010, of which
the promissory note you personally signed is hereto attached.
That after such credit become due and demandable, my client respectfully demand
payment from your part in many occasions to which you refuse to pay to this date.
You are already warned that if you failed to pay or contact my client or this office
until the end of the month of July regarding any payment or settlement, and to give
any reasonable explanation on the reason of your default, this office will use the full
force of the law by resorting to file a complaint against you in court to oblige you in
performing your obligation plus the damages incurred by my clients from your
avoidance.
Let me remind you the expensive cost of litigation and the damages which you will
pay in case we already instituted an action against you which could tarnished as
well your good standing in the business community, thus, we are giving you five
days to resolve this matter.
Furthermore, we are legally advising you to take immediate action and take this last
opportunity to resolve this matter once and for all to avoid the further severance of
the consequences due to you inaction.
Please be guided accordingly.
ATTY. NIEL S. DEFENSOR
Counsel for Ms. Annie B. Tucon
DEFENSOR & ASSOCIATES LAW OFFICE
Roll of Attorney No. ___________;

PTR No.______________;
IBP No.____________;
MCLE Compliance No. _______________;

Republic of the Philippines

Regional Trial Court
Branch 24, Bacolod City

ANNIE B. TOCUN
Plaintiff,
-versus-

Civil Case No. 2012-235

For: Sum of Money

LIZA C. PANTEROS
Defendant,
COMPLAINT
PLAINTIFF, by the undersigned counsel and to this Honorable Court, most respectfully
states:
1. Plaintiff Annie B. Tocun of legal age, single, and a resident of No. 21 Alta Vista
Subdivision, Brgy. Singcang, Bacolod City, while defendant Ms. Liza C. Panteros, of
legal age, single, and residing in 18 Rosario Heights, Brgy. Camingawan Bacolod City, at
which address the parties herein may be served with summons and other court processes;
2. That on August 8, 2010, defendant borrowed the amount of Six Hundred Thousand Pesos
from the plaintiff, with the legal interest of 12% per annum, payable on or before August
8, 2010, in accordance with the promissory note executed by the defendant on the said
date. Photocopy of the promissory note is herewith attached and marked as Annex A
and made integral part hereof.
3. Notwithstanding repeated verbal demands of the plaintiff, and the written demands
through this counsel marked herewith as Annex B was made to secure the payment of
lawful obligation from Ms. Liza C. Panteros, the defendant failed and refused and
continue to refuse to pay his lawful obligation.
4. As a result, plaintiff was constrained to secure the services of counsel to protect his
interest and to file this complaint and to incur a litigation cost and attorneys fees of One
hundred Fifty Thousand Pesos, (Php 150,000.00) which should be assessed against the
defendant.
WHEREFORE, it is most respectfully prayed of this Honorable Court that after due
hearing, judgment be rendered in favor of plaintiff and against the defendant in this manner:
1. Ordering the defendant to pay plaintiff the amount of Six Hundred Thousand Pesos, plus

interest thereon at the rate of 12% per annum starting August 8, 2009 until fully paid; and
2. Ordering the defendant to pay the cost of this litigation and attorneys fees in the amount
of One Hundred Fifty Thousand Pesos (Php 150, 000.00)
Plaintiff likewise prays for such other and further relief or reliefs as this Honorable Court
may deem just and equitable in the premises.
Bacolod City, December 8, 2011.
SUBSCRIBED AND SWORN to before me this 6th day December, 2011 at Bacolod City
Philippines and that the affiant exhibiting to me his Passport No. ABZ1515142 issued at Iloilo,
City on September 26, 2011 and his CTC No. 001187325 issued at Bacolod City on December 2,
2011.
ATTY. NIEL S. DEFENSOR
Counsel for Ms. Annie B. Tucon
DEFENSOR & ASSOCIATES LAW OFFICE
Roll of Attorney No. ___________;
PTR No.______________;
IBP No.____________;
MCLE Compliance No. _______________;

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, Annie B. Tocun, of legal age and with residence address of No. 21 Alta Vista
Subdivision, Brgy. Singcang, Bacolod City, after duly having been sworn, depose and say:
1. That I am the plaintiff in the above entitled complaint:
2. That I have caused the preparation of said complaint;
3. That I have read the allegations therein contained, and that the same are true and correct
to my personal knowledge and/or based on authentic records;
4. That 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
action or other claim is pending therein; and if I should thereafter learn that the same or
similar action or claim has been filed or is pending, I shall report that fact within five (5)
days therefrom to the court wherein the aforesaid complaint or initiatory pleading has
been filed.
Witness my hand this 8th day of December at Bacolod City, Philippines.
ANNIE B. TOCUN
Affiant

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