REPUBLIC OF THE PHILIPPINES

NINTH JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 1, Zamboanga City

MIRA SOL,
Plaintiff, Civil Case No. 50487
-versus- For: Collection of Sum of
JUAN FELIPE, Money with Prayer for Writ of
Defendant. Preliminary Attachment

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COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, and resident of 927 Cornelia St.

Brgy. Pasonanca, Zamboanga City; defendant is also a Filipino, of
legal age and resident of 965, Canelar St., Zamboanga City, where
he may be served with summons and other processes.

2. Sometime in July 2018, and over a period of six (6) months,

defendant borrowed Five Hundred Thousand Pesos (P500,000 )
from plaintiff. Defendant promised to pay the amount on June 20,
2019.

3. Despite repeated written demands of plaintiff, defendant failed and

has refused to pay any amount to plaintiff. A copy each of plaintiff’s
two (2) demand letters is attached as ANNEX A and B.

4. Resort to the Barangay Conciliation process proved fruitless as

defendant failed to appear, despite notice on him to appear. Thus, a
Certification to File Action, a copy of which is attached as ANNEX
C, was issued by the Barangay Chairman.

5. Defendant’s obligation is due and demandable and plaintiff is

entitled to the payment of the entire amount of Five Hundred
Thousand Pesos (P500,000 ) plus legal interest.
6. By reason of defendant’s unreasonable failure and refusal to pay
his due and demandable obligation, plaintiff was forced to engage
the services of counsel to vindicate her rights thereby committing
herself to pay legal expenses amounting to Fifty Thousand Pesos
(P50,000.00).

7. WHEREFORE, plaintiff respectfully prays for judgment in his favor

through a Decision directing defendant to pay him NINE
HUNDRED THOUSAND PESOS (P900,000.00), with legal
interest, as ACTUAL DAMAGES and FIFTY THOUSAND PESOS
(P50,000.00) as Attorney’s Fees.