DEMAND LETTER

March 13, 2020

Pedro Santos
Resident of 123, Alalum,
San Pascual, Batangas
ZIP CODE 4332

This letter will serve as a formal notice that you are in default of payment of
obligation to repay P530,000.00 which was in consideration of your purchases
of poultry feeds and supplies made by you on different dates.

This amount has been overdue since the day we made extrajudicial demand on
March 13, 2020 and it has been ten days since the receipt of our demand and
you have failed to repay the same despite repeated demands by us.

Unless the payment of the above sum is received by us in full within ten days of
the days of this letter, we would have no alternative but to exercise whatever
remedies and rights we have under the law to enforce such payment including
but not limited to institution of legal proceedings against you to recover the
above amount, together with accrued interest and legal expenses.

Kindly govern yourself accordingly.

Yours truly,

Juan de la Cruz
 Republic of the Philippines

6TH JUDICIAL REGION

Regional Trial Court

Branch _____

LIPA CITY

JUAN DELA CRUZ, Civil Case No. _____________

Plaintiff FOR: COLLECTION FOR A SUM OF

MONEY WITH DAMAGES

- versus -

PEDRO SANTOS,

Defendant

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

COMPLAINT
 Plaintiff, through the undersigned counsel unto this Honorable Court, hereby
respectfully avers:

1. That plaintiff is, Juan de la Cruz., Filipino, of legal age, married and a
resident of C. Tirona St., Batangas City, is a sole proprietor engaged in the sale of
poultry feeds and supplies, doing business under the name Juan Poultry Supply, with
business address at C, Tirona St., Batangas City, Philippines where summons and
court processes may be served;

2. The plaintiff sells poultry feeds and supplies on cash and on credit subject
to a 5% interest to certain trusted clients. Purchases on account shall be payable
within ten days from the date of the invoice.

3. That on different dates from 2019 to 2020, the defendant purchased from
the plaintiff poultry feeds and supplies totally amounting to five hundred thirty
thousand pesos (PhP530,000.00) evidenced by records account of purchased referred
to as annex A and form part of the record of this case;

4.That on March 13, 2020, we sent a demand letter for the indebtedness of the
defendant because it become due and demandable;

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 One Hundred Thousand
Pesos (PhP 100,000.00) and an appearance fee of Two Thousand Pesos (PhP
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 (PhP 20,000.00) as evidenced by Annex “D” – Official Receipt;

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 thirty thousand (PhP 530, 000.00);

b. moral damages, exemplary damages at the sum discretion of the court;

c. attorney’s fees amounting to One Hundred Thousand Pesos (PhP

100,000.00) and an appearance fee of Two Thousand Pesos (PhP 2,000.00)
per hearing

d. litigation expenses amounting to Twenty Thousand Pesos (PhP 20,000.00).

Other reliefs and remedies deemed just and equitable under the foregoing
premises are likewise prayed for.

Batangas City, December 20, 2020.

ATTY. DANIEL EVAN NERVEZA

Counsel for Petitioner

NERVEZASILVA Law Office, Balintawak, Lipa, Batangas City

 Roll of Attorneys No. 54321

PTR NO. 654321, 01/06/14, Lipa City

IBP NO. 123456, 01/04/14, Lipa City

MCLE Comp. No. IV-0009876, 01/02/14

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF ILOILO ) SS.

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

VERIFICATION AND CERTIFICATION

I, JUAN DELA CRUZ, Filipino, of legal age, married and a resident of C.

Tirona St., Batangas City, 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.

(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 20th day of

December 2020 at Batangas city, Philippines.

IVANNA ALAWI
 Affiant

TIN 98765-003; Batangas City

SUBSCRIBED AND SWORN to before me, this 20th day of December 2020,
affiant exhibiting to me his Tax Identification Card as shown above below his name
as competent evidence of his identity.

ATTY. DANIEL EVAN NERVEZA

My Commission No. is 58

Expires on December 31, 2015

NERVEZASILVA Law Office, Banlintawak, Lipa city, Batangas

province

Roll of Attorneys No. 54321

PTR NO. 654321, 01/06/14, Lipa City

IBP NO. 123456, 01/04/14, Lipa City

 MCLE Comp. No. IV-0009876, 01/02/14

Doc. No. 5;

Page No. 2;

Book No. 1;

Series of 2014;