REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 119
Pasay City

PETER PARKER, REPRESENTED

BY HIS GUARDIAN MAY PARKER
Plaintiff,
Civil Case No. 2019
-versus-
MIDTOWN TRAVEL AGENCY
Defendant.
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COMPLAINT
Plaintiff, by counsel respectfully states that:
1. He is a Filipino Citizen, a minor, represented by his guardian May
Parker, a Filipino Citizen, both residing at 1940 Donada St. Barangay
34, Pasay City.

2. Defendant is a travel agency corporation duly organized and existing

under the Laws of the Philippines with principal address at 1941 San
Juan St., Pasay City.

3. On June 17, 2019, the plaintiff, together with his friends, organizes a
summer field trip to Europe by availing the services of the defendant.

4. That the plaintiff agreed to pay travel package fee of Php 420,000.00.

5. The agreed itinerary is that from Venice, Italy the trip will continue to
Paris, London where the plaintiff told his friend Ned Leeds that he plans
to confess his feelings to his classmate, MJ Jones.

6. As a first cause of action, the defendant redirects the route from

Venice, Italy to Prague, Czech Republic which is against the will of the
plaintiff and violation of the contract.

7. As a second cause of action, from being unable to confess his feelings

to MJ Jones, the plaintiff suffered shame, humiliation and
embarrassment from his friends.

8. As a result, the plaintiff demanded the defendant to refund their entire

payment for the trip.
 9. The defendant refused claiming that they are no longer liable as the trip
has ended and such was an upgrade from their previous package.

10. Due to such refusal, the dispute was referred to the Katarungang
Pambarangay, but the parties failed to arrive at a settlement.

11. On the account of the defendant’s refusal to refund the payment,

plaintiff was compelled to initiate the suit and hire the services of
counsel for the amount of Php 150,000.00.

PRAYER
WHEREFORE, it is respectfully prayed that a judgment be rendered ordering
the defendant:
1. To pay for actual damages worth Php 420,000.00.
2. To pay for moral damages amounting to Php 50,000.00.
3. To pay the costs of the suit and attorney’s fees for the amount of Php
150,000.00.
4. To pay for other just and equitable remedies under the premises.

Done this 24th day of July 2019 in Pasay City, Philippines.

ATTY. ZYREM EUNICE Z. LACDAO

Counsel for Plaintiff
Notary Public
PTR No. 123, March 23, 2016
IBP Lifetime No. 123456, March 23, 2016
Roll No. 123
MCLE No. 1234
TIN No. 418-461-257-000
CTC No. 123456789, March 23, 2016.

REPUBLIC OF THE PHILIPPINES )

CITY OF PASAY ) S.S.

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
I, May Parker, Filipino citizen, of legal age, a widow, and a resident of
1940 Donada St., Barangay 34, Pasay City, Philippines after having been
sworn in accordance with law do hereby depose and say that:
1. I represent the minor plaintiff in the above-stated case as his guardian;

2. I, for the minor plaintiff, caused the preparation of the foregoing

complaint;

3. I have read all the contents and allegations thereof and acknowledge
that the same is true and correct of my knowledge and belief;
4. I hereby certify that I have not commenced any other action or
proceedings involving the same issue in any court, tribunal or quasi-
judicial agency, that to the best of my knowledge no action or
proceeding is pending in any court, tribunal or quasi-judicial agency;
that if there are any such action or proceeding which is either pending
or terminated, I must state the status thereof; and that if I should
thereafter learn that a similar action has been filed or pending before
any court, tribunal or quasi-judicial agency , I undertake to report the
fact within five(5) days therefrom to the court or agency wherein the
original pleading and sworn certification completed herein have been
filed.

IN WITNESS WHEREOF, I have hereto affixed my signature on this

24th day of July 2019 in the City of Pasay, Philippines.

(SGD.)MAY PARKER
Affiant/ Plaintiff

Doc. No. 123

Page No. 12
Book No. 3
Series of 2019.