REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
MANDAUE CITY, BRANCH VIII

JUAN ILOK,
Plaintiff

-versus- CIVIL CASE No. 3425224

FOR: COLLECTION OF SUM OF MONEY

BRAD ARMPIT,
Defendant

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COMPLAINT

PLAINTIFF, through the undersigned counsel, unto this Honorable Court

respectfully alleges:

1. Plaintiff is of legal age, Filipino, single and a resident of Pardo, Cebu City;

2. That the defendant BRAD ARMPIT is likewise of legal age similarly residing in
Pardo, Cebu City where he could be served with summons and other processes of the court;

3. That on March 7, 2007, the defendant obtained a loan from the plaintiff in a
sum of One Hundred Fifty Thousand pesos (150,000.00) to be paid on July 31, 2007 through
an oral agreement witnessed by his two friends, Pedro Siponon and Jose Kogmohon;

4. That on July 20, 2007, the defendant went to the house of Juan to pay Fifty
Thousand pesos (50,000.00) but Juan was not there so he gave the money to the son of Juan
named John, who is a 17 years old, a minor;

5. That the son of the plaintiff never gave any money to the plaintiff and eloped
with his girlfriend to Tawi-tawi;

6. That on July 31, 2007, Brad went to Juan’s house and gave Juan the
remaining One Hundred Thousand pesos (100,000.00) and told Juan that he already gave Fifty
Thousand Pesos (50,000.00) to John last July 20, 2007;

7. The defendant told the plaintiff that it is not his responsibility anymore since
he already gave the money to the son of the plaintiff who is a minor;

8. The plaintiff argued that the said alleged payment should not be counted as
he has never received the money;

 9. The plaintiff and the defendant argued over the matter through the barangay
but they failed to settle the issue, hence, the barangay captain issued a certification to file
action in court;

10. The plaintiff, through his counsel, send a demand letter to Brad but Brad did
not comply with the Demand Letter, prompting the plaintiff to resort to judicial action;

WHEREFORE, Plaintiff respectfully prays for judgment in its favour through a

decision directing the defendant:

a. To pay Plaintiff the sum of Fifty Thousand Pesos (50,000.00) with interest at
12% as penalty from July 31, 2007 until the full amount is paid;

b. Attorney’s Fees at 10% of the principal amount;

c. the cost of the suit

Other just and equitable reliefs are also prayed for.

Pardo, Cebu City, January 30, 2018.

ATTY. CHARLIEMAGNE J. CRABAJALES

Counsel for the plaintiff
Rock III Building, S.B. Cabahug St., Ibabao, Mandaue City, Cebu
Attorney’s Roll No. 093811
IBP No. 24512-01/01/18-Cebu
PTR No. 33523-01/01/18-Cebu
MCLE Compliance No. IV-009831389 - November 18, 2016