Republic of the Philippines

7th Judicial Region

REGIONAL TRIAL COURT
Branch __
Talisay City

MILO, Civil Case No. CV-______

Plaintiff, For: Collection of Sum of
Money with Damages
-versus-

JIFEL,
Defendant.
x--------------------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable

Court, hereby respectfully avers:

1. That plaintiff, Milo is of legal age, Filipino, married, and a

resident of Pooc, Talisay City, Cebu while the defendant, Jifel is also
of legal age, Filipino, married, and a resident of Pooc, Talisay City,
Cebu where summons and court processes may be served;

2. That on February 14, 2000, the defendant borrowed from

the plaintiff a sum of money amounting to Five Hundred Thousand
Pesos ₱500,000.00) evidenced by a promissory note indicating the
amount loaned and the maturity date which is one year from the
loan date herein attached as Annex “A” and form an integral part of
this complaint;

3. That as shown in the attached promissory note, the

indebtedness of the defendant has become due and demandable on
February 14, 2001;

4. That despite plaintiff's repeated demands, both written and

verbal, defendant failed, neglected and refused to fulfill obligations
without just and valid grounds to the continued damage and
prejudice of plaintiff, as evidenced by Annex “B” – Demand Letters;

5. That the plaintiff in order to enforce his rights and interests,

has sought the services of a legal counsel with attorney’s fees
amounting to Eighty Thousand Pesos (₱80,000.00) and an
appearance fee of Two Thousand Pesos (₱2,000.00) per hearing as
evidenced by Annex “C” – Contract for Legal Services;
 6. That the plaintiff has paid for litigation expenses amounting
to Twenty Thousand Pesos (₱20,000.00) as evidenced by Annex “D”
– Official Receipt; and

7. That the plaintiff has suffered moral damages at the sum

discretion of the Honorable Court;

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. the sum of Five Hundred Thousand Pesos (₱500,000.00) as

stipulated in the promissory note;

b. moral damages, exemplary damages at the sum discretion

of the court;

c. attorney’s fees amounting to Eighty Thousand Pesos

(₱80,000.00) and an appearance fee of Two Thousand Pesos
(₱ 2,000.00) per hearing; and

d. litigation expenses amounting to Twenty Thousand Pesos

(₱20,000.00).

Other reliefs and remedies deemed just and equitable under

the foregoing premises are likewise prayed for.

Talisay City, March 6, 2002.

ATTY. ELMER M. TASONG

Counsel for Plaintiff
Tasong Law Office, Collinwood Vil., Talisay City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/02, Talisay City
IBP NO. 123456, 01/04/02, Talisay City
MCLE Comp. No. IV-0009876, 01/02/02

2
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF CEBU) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

FOR NON-FORUM SHOPPING

I, MILO, of legal age, Filipino, married, and a resident of Pooc,

Talisay City, Cebu, after being sworn in accordance with law, hereby
depose and say:

(1) That I am the Plaintiff in the above-entitled case;

(2) That I have caused the preparation of the above Complaint

and I have read the same and understood the contents thereof;

(3) That the allegations contained therein are true and correct
of my own personal knowledge and based on authentic records; and

(4) That I further certify that: 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 and,
to the best of my knowledge, no such action or proceeding is pending
therein; 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 6th

day of March 2002 at Talisay City, Philippines.

MILO
Affiant
TIN 98765-003; Talisay City

3
 SUBSCRIBED AND SWORN to before me, this 6th day of
March 2002, affiant exhibiting to me his Tax Identification Card as
shown above below his name as competent evidence of his identity.

ATTY. JOSE SAN JUAN

Notary Public
Commission No. NP-066, Cebu City
Until December 31, 2005
SC Roll of Atty. No. 38925
IBP Lifetime Roll No. 23984
IBP Cebu Chapter
PTR No. Z729993, 12-03-2005, Zambales
MCLE Compliance No. II-0023834, 08-
01-2018, Cebu City

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2002;