REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Bacolod City
Branch XI
SANSA STARK
Plaintiff,

versus

Civil Case No. 112334

FOR:
Recovery
of
Actual
Damages, Moral Damages and
Attorneys Fees

DANIEL DEL ROSARIO VI

Defendant.
x----------------------x
COMPLAINT
COMES NOW, plaintiff, SANSA STARK, by counsel and unto this
Honourable Court, most respectfully avers that:

1. Plaintiff, SANSA STARK, is Filipino, of legal age, single and residing in

Winterfell Subdivision, Lacson St., Bacolod City, where she may be
served with summons, papers and other process of this Honourable
Court;
2. Defendant, DANIEL DEL ROSARIO VI, is a Filipino, of legal age, single
and residing in Riverrun Subdivision, Brgy. Estefania, Bacolod City,
where he may be served with summons, papers and other process of
this Honourable Court;
3. The defendant met SANSA STARK last September 2015 in a friends
wedding and thereafter courted the latter until the mid of January
2016 when they both finally decided to have a formal dating
relationship;
4. Just three (3) months into their relationship, the defendant asked
SANSA STARKs hand in marriage;
5. When SANSA STARK consented to finally be wed with the defendant,
they both chose June 30, 2016 to be the date when they would swear
before the church and the community, and show everyone their
undying love;
6. Since the preparation left the parties constraint with time, the
defendant then contacted Marjorie Tyrel, a high-ranking wedding
coordinator in Tyrels & High Garden to assist them;
7. The initial contract with Marjorie Tyrel was for her to spearhead the
entire wedding preparation from the choosing of venue until the
flower arrangements and would only ask the parties to choose from

options that she may find. She was specifically instructed by the
defendant to choose the best options regardless of the price. Her
contract was for Php 90,000.00 for the services alone, to be paid in
two (2) separate occasions. A copy of the contract of services is
attached herewith as Annex A.
8. Last April 30, 2016, the defendant, claiming that his account in BDO
was frozen for some unknown reasons, asked SANSA STARK to pay the
first half, Php 45,000.00 to be precise, of Marjorie Tyrels fees. A copy
of the receipt for Marjorie Tyrels services is attached herewith as
Annex A.1.
9. Upon learning about the status of his account in the North Central
Bank, herein defendant booked a one-way ticket straight to Manila
City, Philippines on May 5, 2016, to resolve the alleged issue. He made
mention to SANSA STARK that aside from resolving the banks errors,
he will also be personally inviting some of his relatives in Laguna.
Attached herewith is a machine-copy of the defendants plane ticket as
Annex B.
10.

Under the assurances of herein defendant, SANSA STARK

agreed to cover the necessary expenses while he is resolving
complications with the North Central Bank in Manila and the former will
be reimbursed upon the defendants return;

11.

Last May 10, 2016, upon efficient research and a highly

organized coordination, Marjorie Tyrel was able to present before the
spouses two options for the venue: (1) St. Ignatius Chapel PMA Baguio
for the ceremony and Baguio Country Club for the reception, or (2)
Balesin Spa beachfront for the ceremony and The Balesin Royal Villa
Salon for the reception;

12.

Upon learning of the options, the defendant called SANSA

STARK and asked her to choose Balesin as he has this fascination with
seawater. SANSA STARK then contacted Marjorie Tyrel and told her of
their decision;

13.

Immediately, on May 12, 2016, Marjorie Tyrel called the Balesin

Hotels and made a reservation for their Balesin Spa beachfront and
The Balesin Royal Villa Salon on June 30, 2016. Accordingly, the hotel
coordinator checked and confirmed that the date is open for bookings,
and asked for the detailed itinerary of the wedding. Marjorie Tyrel then
sent an email to the hotel coordinator and asked the latter to provide a
rough estimate of the costs;

14.

On May 13, 2016, the hotel coordinator responded with the

detailed computation of the expenses including the four (4) hotel
rooms to be reserved for the couple, their respective families and the
wedding coordinators team. He made mention that since June is
considered as a peak season in Balesin because of the high demands
of the venue for weddings, an increase of 10% was applied to the
computation. All in all, the cost of the ceremony and reception venue
amounted to Php 490,000.00. A copy of the computation made by the
hotel coordinator is herewith attached as Annex A.2.

15.

On the same day, Marjorie Tyrel contacted SANSA STARK and

informed the latter about the Balesins computation. The latter asked

to give her until the end of the day to confirm as she will be calling the
defendant for confirmation;
16.

Meanwhile, while attempting to contact the defendant, SANSA

STARK went ahead and posted a Facebook status of her list of
entourage for the wedding and even sent personal messages to each
one of them. She created a massive list of 100 visitors and 90 persons
as part of her entourage;

17.

As it was nearing the end of the day and being unable to reach
the defendant, SANSA STARK confirmed with Marjorie Tyrel about the
Balesin reservation. She then asked the latter to create an online
temporary invitation to be sent to all their guests within the week;

18.

On May 14, 2016, Marjorie Tyrel confirmed with the Balesin

Hotels the reservation on June 30, 2016 and made the full deposit of
Php 490,000.00 to their BDO account. Attached herewith is the deposit
slip as Annex A.3.

19.

On the same day, Marjorie Tyrel contacted Tyrion Lannister, a

prominent programmer in Cebu City to create an online temporary
invitation, as ordered by SANSA STARK. The programmer agreed to
create the same for a fee Php 40,000.00 for creation and management
of the website until after four weeks after the wedding. This
agreement was sealed by a deposit made by Marjorie Tyrel to Tyrion
Lannisters account in BDO. Attached herewith is a copy of the deposit
slip made to the programmers account as Annex A.4.

20.

As SANSA STARK was anxious of the preparation and

overwhelmed of her task to confirm the attendance of their guests, she
tried to call the defendant last May 15, 2016 to ask for help. As she
was able to reach him, the latter informed him that he will be
returning to Bacolod City with his family and few of his relatives on
May 30, 2016. The defendant asked SANSA STARK to continue with
the preparations and that he will be seeing her on May 30, 2016;

21.

Despite being frantic, SANSA STARK followed her personal

calendar of bookings she has to accomplish right before their dream
wedding. Charging to her dedication, she was able to confirm their 80
visitors including family members and 20 guests for her entourage.
She was likewise able to complete her task of choosing her and her
entourages wedding gown from Francis Libiran and paid the latter Php
600,000.00 all in all. Attached herewith is the deposit slip made as
payment for the gown and other dresses as Annex A.5.

22.

All being in place, SANSA STARK was very excited to bring the
news to her would-be husband and tried to call him last May 28, 2016.
However, the defendants sister was the one who received the call. The
latter informed SANSA STARK that the defendant was very busy with
business meetings and that he will be calling her again should time
permit;

23.

May 30,2016 came and the defendant never came home nor
contacted SANSA STARK;

24.

On June 1, 2016, SANSA STARK called the defendant again to

confirm the possible rebooking of flight but to her surprise, the
defendant answered and bluntly told her that the wedding is off. He

made mention that his family does not approve of his short-term love
affair with a Bacolodnon and that he was already apparently set to wed
another Australian national;
25.

On June 15, 2016, SANSA STARK sent an initial demand letter

to herein defendant asking the latter for the promised reimbursement
for all the actual costs. The demand letter specifically enumerated the
payments made including the receipts. A copy of the same is herein
attached as Annex C.

26.

Unheeded, SANSA STARK sent another letter last June 29, 2016
representing the final demand letter reiterating the demands made in
the initial letter. A copy of the final demand letter is herein attached as
Annex C.1.

27.

Aggrieved, SANSA STARK filed this action before this Honourable

Court.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honourable Court that

after due hearing, judgment be rendered in favour of plaintiff and against the
defendant in this manner:

1. Order the defendant to pay the plaintiff the amount of One Million One
Hundred Seventy Five Thousand (Php 1,175,000,000) Philippine
Currency representing the following payments made in consideration
of the promised marriage, plus interest thereon at the rate of 12% per
annum from June 15, 2016 until the same is fully paid:
a. Forty Five Thousand Philippine Currency (Php 45,000.00) as
initial payment made to the wedding coordinator,
b. Four Hundred Ninety Thousand Philippine Currency (Php
490,000.00) as full payment of the Balesin Hotels reservation,
c. Six Hundred Thousand Philippine Currency (Php 600,000.00) as
payment for the wedding and entourage gowns,
d. Forty Thousand Philippine Currency (Php 40,000.00) as payment
for the programmers creation of online website and online
invitations.
2. Ordering the defendant to pay the plaintiff moral damages amounting
to One Hundred Thousand Philippine Currency (Php 100,000.00) for
besmirched reputation, mental anguish, moral shock, wounded
feelings, social humiliation and serious anxiety brought about by the
cancellation of the wedding.
3. Ordering the defendant to pay the cost of this suit and attorneys fees
of Sixty Thousand Philippine Currency (Php 60,000.00).
Plaintiff likewise prays for such other and further relief or reliefs as this
Honourable Court may deem just and equitable in the premises.

Bacolod City, Philippines, July 21, 2016.

YNZON AND ASSOCIATES

Counsel for the Plaintiff.
3rd Floor Kings Landing Building
Door No. 10, Circumferential Rd
For the firm:

Nilsy Ynzon
NILSY N. YNZON

IBP No. 827847, 6/8/16, BC

PTR No. 576784, 6/8/16, BC
Attorneys Roll No. 12345
MCLE Compliance No. 11-055555

SUBSCRIBED and SWORN TO before me this 21 st day of July, 2016

at Bacolod City, Philippines, affiant exhibiting to me his Drivers License
EB29990 issued on 13th day of April 2013 at Bacolod City, Philippines.

Panini Mormont
PANINI MORMONT
NOTARY PUBLIC

IBP No. 827849, 6/8/16, BC

PTR No. 236767, 6/8/16, BC
Attorneys Roll No. 30678
MCLE Compliance No. 11-0578099

Doc. No. 01
Page No. 01
Book No. 01
Series of 2016

VERIFICATION AND CERTIFICATION OF

NON-FORUM SHOPPING

I, SANSA STARK, of legal age, resident of Winterfell Subdivision,

Lacson St., Bacolod City, under oath, do hereby depose that:
1.

I am the plaintiff in the said case;

2.
I have caused the preparation of the same and I attest to the veracity
of all the allegations stated herein;
3.
I have read and understood all the allegations herein and that I attest
to the authenticity and veracity of all the documents attached herein as
based on existing and authentic records;
4.
I further certify that I have not commenced or filed any claim involving
the same issues herein with any other Court, tribunal or quasi-judicial agency
or I am not aware of any such other case or claim pending before any other
court, tribunal or quasi-judicial agency; and
5.
Should I thereafter learn of the filing or pendency of such similar
action or claim, I will inform this Honourable Court of such fact within five (5)
days from knowledge thereof.

IN WITNESS WHEREOF, I have hereunto affixed my hands this 21 st

day of July, 2016 at Bacolod City, Philippines.

Sansa
Stark

SANSA STARK
Affiant