Submitted by: Eloisa C.

Palmones REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION METROPOLITAN TRIAL COURT Branch _____, Makati City DE LIMA, LEILANIE Plaintiff, -versusCivil Case No. ________ FOR: SUM OF MONEY

HENARRES, KIMMIE Defendant. X----------------------------------------------X

VERIFIED COMPLAINT
PLAINTIFF by counsel, unto the Honorable Court, most respectfully avers that:

1.

Plaintiff is of legal age, Filipino, single and resident 17 Hernaez

Street, Makati City; 2. Defendant is of legal age, Filipino, single with residence at Lot 4,

Block 6, Phase 1, Mahogany Place, Taguig City where she may be served with summons and other judicial processes;

3.

That on 20 March 2012, defendant executed a promissory note in

favor of the plaintiff in the amount of FOUR HUNDRED THOUSAND PESOS (P400,000.00) payable within three months from the date of the promissory note (attached herewith as Annex A is a copy of the promissory note); 4. That the three month period had elapsed and despite demands

made orally and in writing (attached herewith as Annex B is a copy of

the said demand letter) by the plaintiff, defendant refused and failed to pay the amount stated in the promissory note.

5.

That due to the unjust refusal of defendant to comply with the

demands, plaintiff was compelled to file the instant action engaging the services of counsel in the amount of P10,000.00.

PRAYER
WHEREFORE, plaintiff respectfully prays for judgment in her favor through a Decision directing defendant to pay her FOUR HUNDRED THOUSAND PESOS (P400,000.00), with legal interest and TEN THOUSAND PESOS (P10,000.00) as Attorneys Fees. Other just and equitable reliefs are also prayed for. Makati, June 26, 2012.

Atty. ELOISA C. PALMONES Counsel for the Plaintiff Penthouse B, Hilton Tower 163 Legazpi St., Legazpi Village, Makati City 1229 Telefax No. (02) 8128839 PTR No. 3180080 01/05/2012 Makati City IBP Lifetime Member Roll No. 000000 Roll of Attorneys No. 63534 MCLE Compliance No. III-0003940; 7/06/11

Copy Furnished (by personal service): KIMMIE HENARRES Lot 4, Block 6, Phase 1, Mahogany Place, Taguig City

VERIFICATION AND CERTIFICATION

I, LEILANIE DE LIMA, of legal age, single, Filipino, and resident of 17 Hernaez Street, Makati City, after having been sworn to in accordance with law, do hereby depose and say that:
2

1. I am plaintiff in the instant case; 2. I have caused the preparation of the Complaint, and I have read the contents thereof and the same are true and correct to the best of my personal knowledge and beliefs; 3. The documents attached therein are authentic and are faithful reproduction of the original; 4. I hereby certify that I have not filed similar action or complaint involving the same parties and cause of action; that there is no pending case between the same parties or cause of action before any court or tribunal, but should I learn that there is such action, I will undertake to inform the Honorable Court of such pendency, within five (5) days from knowledge. IN WITNESS WHEREOF, I hereby affixed my signature this 26th day of June 2012, in Makati City, Philippines. Leilanie De Lima Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, this 26th day of June 2012, in the City of Makati, Philippines, affiant exhibiting to me her Passport No.xxv12345 issued on December 7, 2011 by the Department of Foreign Affairs, Manila City.

Atty. ANNABELLE ROMA # 14 Salcedo Street, Makati City Telefax No. (02) 9228827 PTR No. 5165502 - 04/15/12 - Makati City IBP No. 823089 04/15/12 - Makati City Roll of Attorneys No. 59022 MCLE Compliance No. III-0014996; 4/29/12

Doc. No.1 Page No.3 Book No. 4 Series of. 2012