REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

5th Judicial Region
Branch ____, Legazpi City

City Government of Legazpi, Civil Case No. _____

Plaintiff, For: Collection of Sum of
Money

MV Jake Vincent Ocho,

Defendant.
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COMPLAINT

PLAINTIFF, through counsel, most respectfully avers:

(1.) That plaintiff, Alexander Sison is a Filipino citizen, of legal

age, single and a resident of 111 Libertad St. Sampaloc Manila,

whereas, defendant Juan Jamero is likewise a Filipino, of legal age,

single, and residing at 222 Juan Luna St., Tondo Manila, at which

address the party herein may be served with summons and other court

processes;

(2.) That on January 3, 2008, defendant borrowed from plaintiff

the amount of one million pesos (Php. 1,000,000.00) , which

indebtedness is due and payable on or before January 3, 2009, with an

interest at the rate of 12% per annum within one (1) year, in

accordance with the promissory note executed by the defendant on the

 said date. Photostatic copy of said promissory note is attached and

marked as Annex “A” and made as a integral part hereof;

(3.) That the defendant has failed and refused and still fails and

refuses to pay the said indebtedness on due date, with corresponding

interest thereon to the herein plaintiff, despite repeated requests and

demands.

(4.) That the plaintiff served several demands to the defendant,

attached is the last demand letter executed on July 01, 2009 by the

plaintiff as annex “B” and made as an integral part hereof;

(5.) That the defendant shall pay for the attorney’s fees and

expenses of litigation in the amount of Php. 75,000.00 and a fee of

P3,000 for every appearance in court, and to pay the cost of this suit;

(6.) That the plaintiff is willing to put up a bond for the issuance

of a preliminary attachment in an amount to be fixed by the court, not

exceeding the sum of one million pesos which is the plaintiff’s claim

herein;

PRAYER

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

pending hearing of this case a writ of preliminary attachment be issued

against the property of the defendant to serve as security for the satisfaction

of any judgment that may be recovered herein; and that after due hearing on

the principal cause of this action, judgment be rendered against the

defendant for the sum of the following:

(1.) Ordering defendant to pay plaintiff the amount of one

million pesos (Php. 1,000,000.00) plus interest thereon at the rate of

 12% per annum from January 3, 2009, and until the same is fully paid;

and

(2.) Ordering defendant to pay the attorney’s fees and expenses

of litigation in the amount of Php. 75,000.00 and a fee of P3,000 for

every appearance in court, and to pay the cost of this suit;

Plaintiff likewise prays for such other and further relief or reliefs as this

Honorable Court may deem just and equitable under the premises.

Manila, Philippines, September 01, 2009.

Counsel for the Plaintiff

REPUBLIC OF THE PHILIPPINES )

PROVINCE OF ALBAY )
CITY OF LEGAZPI ) S.S.

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VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
I, Alexander Sison, Filipino, of legal age, single, after having been duly

sworn in accordance with law, deposes and states that:

1. That I am the plaintiff in the above-stated case;
2. That I have caused the preparation of the foregoing complaint;
3. I have read and understood the allegations therein contained

and the same are true and correct of my own personal

knowledge and based on authentic records;

4. I have not commenced any other action or proceeding involving

the same issues in the Supreme Court, the Court of Appeals, or

 any other tribunal or agency; to the best of my knowledge and

belief, no such action or proceeding has been filed or is pending

before the Supreme Court, the Court of Appeals, or other

tribunal or agency; that I should thereafter learn that a similar

action or proceeding has been filed or is pending before the

Supreme Court , the Court of Appeals, or any other tribunal or

agency, I under take to report that fact within five (5) days

therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 1st day of

September, 2009 in Manila, Philippines.

Affiant
ID No. 1234567
Issued at: Manila, Philippines
Issued on: January 09, 2006

SUBSCIBED AND SWORN TO before me this 1st day of September,

2009, in Manila after showing to me his competent evidence of identity

indicated below his name.

I HEREBY CERTIFY that I personally examined the affiant and I am

satisfied that she voluntarily executed and understood his declaration on the

place and date above written.

Notary Public

Doc. No. __
Page No. __
Book. No. __
Series of 2019
Date and Time Notarized: __________

“ANNEX A”

DEMAND LETTER