REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT,
MANILA, BRANCH __
JUAN DELA CRUZ,
Plaintiff
CIVIL CASE NO. ________
FOR: Sum of Money
And Damages

versus

JOHN R. REYES,
Defendant
x------------------------------------------------x

COMPLAINT
PLAINTIFF, by counsel, respectfully states that:
1. Plaintiff JUAN DELA CRUZ is a Filipino citizen, of legal age,
married and residing at 1234 Zamora Street, Paco, Manila, where he may be
served with court processes, motions, and decision;
2. Defendant JOHN R. REYES is also a Filipino citizen, of legal age,
and residing at 4567 Pedro Gil Street, Paco, Manila where he may be served
with summons and other court processes;
3. On August 1, 2013, defendant executed a promissory note in favor
of the plaintiff in the amount of TEN MILLION (PHP10,000,000.00)
PESOS, Philippine Currency payable within a period of ten months at ONE
MILLION(PHP1,000,000.00) PESOS every month starting September 1,
2013 and every month thereafter until June 01, 2013. The Promissory Note
dated August 01, 2013 reads:
August 01, 2013
I promise to pay to the Order of Juan dela Cruz the sum
of TEN MILLION(PHP10,000,000.00) PESOS, Philippine
Currency, within a period of ten months at ONE
MILLION(PHP1,000,000.00) PESOS per month beginning
September 01, 2013 until June 01, 2013.
SGD. JOHN R. REYES

Copy of Promissory Note dated August 01, 2013 is hereto attached as

Annex A;
4. In payment of his loan obligation, defendant issued ten(10)
postdated checks to cover the ten monthly payments from September 01,
2013 to June 01, 2013;
5. In breach of his obligation, the five(5) checks covering the
payments from February 01, 2013 to June 01, 2013, in the total amount of
FIVE MILLION(PHP5,000,000.00) PESOS, when deposited to plaintiffs
account with the bank were all returned dishonored and unpaid on the
ground closed account. Demands were made upon defendant to make
good the dishonored checks within five(5) working days from receipt of the
notice of dishonor from the bank but defendant failed and refused to pay the
same;
6. Due to the unjust refusal of defendant to comply with the demands,
plaintiff was compelled to engage the services of counsel for which he
agreed to pay an acceptance fee of PHP 20,000.00 plus per appearance fee of
PHP3,000.00. Counsel sent defendant a final demand to pay but despite
receipt thereof, defendant still failed and refused to pay his obligation to
plaintiff. Copy of the demand letter from counsel is attached as Annex B;

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed
that judgment be rendered in favor of plaintiff and against defendant
directing defendant to pay plaintiff the amount of FIVE
MILLION(PHP5,000,000.00) PESOS plus legal interest from date of final
demand plus PHP20,000.00 as and for attorneys fees and the total
appearance fees incurred.
Other just and equitable relief are also prayed for.
Manila, September 28, 2015.
ROMEO R, DELA CRUZ
1234 Zamora Street, Paco, Manila
Roll no. 50000
PTR no. 123456 issued at Manila on Jan 02, 2015
IBP no. 34567879 issued at Manila on Jan 02, 2015
Tel no. 02-456768 cell no. 0915-7777878
romeodelacruz@yahoo.com

VERIFICATION/CERTIFICATION
AGAINST FORUM SHOPPING
I, JUAN DELA CRUZ, Filipino, of legal age, married and with
residence at 1234 Zamora Street, Paco, Manila, after having been duly
sworn to in accordance with law hereby states that:
1. I am the plaintiff in the above-captioned complaint fro collection of
sum of money and damages against defendant Rommel R. Reyes. As such
plaintiff I cause the preparation of the foregoing complaint. I have read and
understood the foregoing complaint and I hereby attest and certify under
oath that the factual allegations therein are true and correct on my personal
knowledge and based on authentic records in my possession;
2. I hereby certify that 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; If I should 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 undertake to report
said fact to this Court within five (5) days therefrom.
IN WITNESS WHEREOF, I have signed this Verification and
Certification on this ___ day of September 2015 in the City of Manila.

JUAN DELA CRUZ

Affiant
SUBSCRIBED AND SWORN to before me this ___ day of
September 2015 in the City of Manila, affiant exhibiting to me his _____ ID
no. ______________.
NOTARY PUBLIC
Doc no. ____
Page no. ____
Book no. ____
Series of 2015.