REPUBLIC OF THE PHILIPPINES

Fourth Judicial Region

REGIONAL TRIAL COURT
Branch ___
Calapan City

LIZ UY,
Plaintiff,

-versus-
CIVIL CASE NO: ___________
For: Collection of Sum of Money

PIA WURZTBACH,
Defendant.

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COMPLAINT

COMES NOW the plaintiff, by the undersigned counsel, and to

this Honorable Court, respectfully alleges:

1. That the plaintiff is of legal age, Filipino citizen and resident of a

resident of Brgy Balite Calapan Ciy Oriental Mindoro;

2. That the defendant is also of legal age, Filipino citizen and

resident of a resident of Brgy Balite Calapan Ciy Oriental
Mindoro where she may be served with summons;

3. That on or about March 17, 2016, defendant obtained a loan of

Php 1,000,000.00 plus 20% interest per annum from the
plaintiff payable within 2 years from the date of the effectivity of
 the Contract of Loan with Chattel Mortgage, attached here as,
Annex “A”;

4. That said loan, now overdue, as evidenced by the attached

contract;

5. That despite notice of the plaintiff, even though it was agreed in

the contract that there is no need of demand for the loan to be
due, the defendant still failed to settle her loan;

6. That the plaintiff filed a complaint to the Barangay

of Balite Calapan City for conciliation and mediation but no
amicable settlement was reached, hence the issuance of a
Certificate to File Action, attached here as Annex “B”;

7. That due to the non-payment of the defendant on the agreed

date of settlement the plaintiff incurred loss amounting to Php
400,000.00 as evidenced by a demand letter sent to the
plaintiff, attached here as Annex “C”;

8. That in the prosecution of this case against the defendant, the

plaintiff incurred attorney’s fees of Php 200,000.00 as
acceptance fee and Php 5,000.00 fee per appearance in court
as evidenced by an engagement letter, attached here as Annex
“D”;

9. That plaintiff executed a judicial affidavit to prove her causes of

action for collection of sum of money against the defendant in
the above-entitled case, and this Judicial Affidavit be marked as
my Annex “E”;

WHEREFORE, it is respectfully prayed that judgment be

rendered against the defendant to pay the plaintiff:

a. The sum of Php 1,000,000.00 representing the principal of the

loan;
 b. The sum of Php 400,000.00 representing the simple interest of
20% per annum for the two year period duration of the loan;
c. The sum of Php 400,000.00 representing the losses incurred;
and
d. Attorney’s fees pf Php 200,000.00 plus Php 5,000.00 fee per
court appearance.

Other equitable reliefs are likewise prayed for.

Calapan City, Oriental Mindoro. August 10, 2018  

  
  
SIGNED  

ATTY JOSEPH ABU BAKHAR 

Counsel for Plaintiff  
3rd Floor ABC Building, Brgy Camilmil,  
Calapan City, Oriental Mindoro  
Roll of Attorneys No. 12345  
PTR No. 1234567/Calapan City/01-05-18  
IBP Lifetime No. 8910112/Calapan City  
MCLE Compliance No. V-0022843;08-12-16  
TIN: 156-277-235-000