REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION

CITY OF PASIG, BRANCH _______

JUAN DELA CRUZ,

Plaintiff,

- versus- CIVIL CASE NO.________

For : SUM OF MONEY

JOSE SANTOS,

Defendant.

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COMPLAINT

NOW COMES the plaintiff in the above-entitled case and by

undersigned counsel, to this Honorable Court respectfully shows:

I

The plaintiff is of legal age and has residence at 125 Reyes St., Pasig

City while the defendant is likewise of legal age and a resident 0f 345 Perez

St., Taguig City, Metro Manila, where he may be served with summons.

II

On September 15, 2009, the defendant obtained a loan from the plaintiff

in the sum of FIVE HUNDRED THOUSAND (Php 500,000.00) PESOS,

upon his promise to pay the plaintiff within one (1) year from the aforesaid

date, duly executing in favor of the plaintiff a promissory note which, in

words and in figures, reads as follows:

P500,000.00 Pasig City

September 15, 2009

For value received, I hereby promise to pay JUAN DELA CRUZ

or order the sum of Php500,000.00 on or before September 16, 2010. With

interest at the rate of One percent (1%) per month. Demand and/or

presentment for payment waived.

S/T JOSE SANTOS

A copy of the aforementioned promissory note is hereto attached

marked as ANNEX “A” and made a part hereof.

III

The defendant failed to pay the amount of Php500,000.00 on the

maturity date of the promissory notes sued upon and, despite repeated

demands, he has, until now, failed and refuse to pay the said amount.

IV

As a consequence of the foregoing, the plaintiff has to litigate and to

engage the services of the undersigned counsel in whose favor he has incurred

the obligation to attorney’s fee in the sum of P50,000.00

PRAYER

WHEREFORE, it is respectfully prayed that this Honorable Court

render judgment ADJUDING THE defendant to pay the plaintiff the sum of

Php500,000.00 with interest thereon at the rate of 1% a month from

September 30, 2009 until fully paid, plus attorney’s fees in the sum of

Php50,000.00.

Pasig City, September 17, 2010.

ROBERTO P. TAN

Counsel for the Plaintiff

666 Banaag St., Ortigas, Pasig

Roll No. 53421

PTR No. 87643, 1/5/09, Makati City

IBP No. 794571, 1/6/09, Pasig Chapter

MCLE Compliance No. 54698, 2/27/09