1.

(a)
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
METRO MANILA
BRANCH _____

ALEXANDER SISON
Plaintiff,
- versus -

Civil Case No:

FOR: Collection of Sum of Money
With Damages

JUAN JAMERO,
Defendant.
x------------------x
COMPLAINT
Plaintiff, through the undersigned counsel unto this Honorable Court,
hereby respectfully states as follows:
1. Plaintiff ALEXANDER SISON is of legal age, Filipino, married, and
a resident of 111 Libertad St., Sampaloc, Manila, Philippines. For
purposes of this action, plaintiff may be served with all orders,
notices, and other processes of this Honorable Court through the
office address of the undersigned counsel indicated below;
2. Defendant JUAN JAMERO is of legal age, Filipino, single, and a
resident of No. 222 Juan Luna St., Tondo, Manila,Philippines, where
summons and other court processes maybe served;
3. That, on January 3, 2008, Defendant obtained a loan from the Plaintiff
in the sum of ONE MILLION PESOS (Php 1,000,000.00), Philippine
Currency, with a promise to pay within one (1) year from the said
date, with an agreed interest of twelve (12) % per annum as
evidenced by a promissory note herein attached as Annex A and
made an integral part hereof;
4. That, after the lapse of the period agreed upon, the Defendant failed to
pay the amount of the loan and its interest; Defendant still has an
Outstanding Balance to Plaintiff amounting to ONE MILLION
PESOS (PhP 1,000, 000.00) plus One Hundred Twenty Thousand
Pesos (Php 120,000.00) representing the total annual interest.

5. That, despite repeated verbal and written demands made by Plaintiff

upon the Defendant, Defendant refused and continuously failing to
pay her obligation to the damage and prejudice of herein Plaintiff;
6. That Plaintiff through his counsel sent a final demand letter to the
defendant demanding for the payment of the loaned amount of
P1,000,000.00 plus interest of 12% per annum. Copy of the demand
letter personally served to the Defendant is hereto attached as Annex
B;
7.

Plaintiff likewise initiated proceedings before the Lupong

Tagapamayapa of Juan Luna St., Tondo, Manila, however, defendant
failed to appear during the scheduled mediation proceeding despite
proper notice, prompting the Lupong Tagapamayapa to issue
Certificate to File Action. A copy of Notice of Hearing and
Certification to File Action are hereto attached as Annex C and
D and made an integral part hereof;

8. That, the Plaintiff in order to enforce his rights and interests, has
sought the services of a legal counsel with attorneys fees amounting
PhP 75,000.00 and an appearance fee of PhP 3,000.00 per hearing as
evidenced by Annex D Contract for Legal Services.

PRAYER
WHEREFORE, premises considered, it is hereby respectfully prayed
before the Honorable Court to render decision in favor of the plaintiff and
order the defendant to pay the following:
a) An amount of ONE MILLION PESOS (Php 1,000, 000.00),
representing Defendant's Outstanding Balance, plus One Hundred
Twenty Thousand Pesos representing the total annual interest at
twelve percent (12%) per annum as stipulated upon in the Promissory
Note;
b) SEVENTY FIVE THOUSAND PESOS as Attorney's Fees plus
Appearance Fee at the rate of PhP 3, 000.00 per court hearing /
conference;
c) Moral damages and exemplary damages at the sound discretion of the
court;
d) The costs of suit.

Plaintiff likewise prays for such other reliefs as may be just and
equitable in the premises.
City of Manila, Philippines, March 28, 2015.

ATTY. LAURENCE SUSAN P. ORTIZ

Counsel for the Plaintiff
Ortiz Law Office, Saampaloc, Manila
PTR No. 22334, 1/17/14, Manila City
IBP No. 44556, 1/10/14, Manila City
Roll of Attorney No. 44661
MCLE Compliance No. VI-010489

Republic of the Philippines

Iloilo City

) S.S.

x--------------------------------------------x

VERIFICATION AND CERTIFICATION

I, ALEXANDER SISON, of legal age, single, Filipino and a resident of
No. 111 Libertad St., Sampaloc Manila, Philippines, after having been duly
sworn in accordance with law, depose and state that:
That I am the Plaintiff in the above-entitled case; That I have caused
the preparation of the above Complaint and I have read the same and
understood the contents thereof; That the allegations contained therein are
true and correct of my own personal knowledge and based on authentic
records.
That I further certify that: (a) I have not theretofore commenced any
other action or proceeding or filed any claim involving the same issues or
matter in any court, tribunal, or quasi-judicial agency; (b) to the best of my
knowledge, no such action or proceeding is pending therein; and (c) if I should
thereafter learn that the same or similar action or proceeding has been filed or
is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5)
days therefrom to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 38th
day of March 2015 at the City of Manila, Philippines.

ALEXANDER SISON
Affiant
NBI ID. 2345, City of
Manila

SUBSCRIBED AND SWORN to before me this 28th day of March

2015 at Manila City, Philippines, affiant exhibiting to me his NBI ID as
shown above below his name as competent evidence of his identity.

WITNESS MY HAND AND NOTARIAL SEAL on the day, year

and place first above written.

ATTY. LAURENCE SUSAN P. ORTIZ

Notary Public for and in the
City and Province of Iloilo
Commission Serial. No. 1989
Valid until December 31, 2015
Ortiz Law Office, Sampaloc, Manila
PTR No. 22334, 01/17/14, Manila City
IBP No. 44556, 01/10/14, Manila City
Roll of Attorney No. 44661
MCLE Compliance No. VI-010489

Doc. No. 1 ;
Page No. 2;
Book No. I;
Series of 2015.