REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch 25, MANILA

EVE CELESTE GARCIA

Plaintiff,
Civil Case No. 23021-SPF
-versus- For: Sum of Money

PEDRO PENDUKO
Defendant.
X-----------------------------------------X

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court,

hereby respectfully states as follows:

1) Plaintiff, is of legal age, single, Filipino, and a resident of 111

Libertad St., Sampaloc, Metro Manila, Philippines while the Defendant is
also of legal age, single, Filipino, and a resident of 222 Juan Luna St.,
Tondo, Metro Manila, Philippines where summons and court proceedings
may be served;

2) That, the Defendant borrowed from the Plaintiff a sum of money

amounting to ONE MILLION pesos (P1,000,000.00), with 12% interest per
annum, as evidenced by a Promissory Note herein attached as “Annex A”
and form an integral part of the complaint;

3) That, the indebtedness of the Defendant has become due and

demandable on January 3, 2009, a year after it was promised in the
promissory note;

4) That, despite repeated verbal and written demands made by the

Plaintiff upon the Defendant, the Defendant has failed to fulfill his
obligation as evidenced by “Annex B”;

5) That, the Plaintiff in order to enforce his rights and interests, has
sought the service of a legal counsel with attorney’s fees amounting
P75,000.00 and an appearance fee of P3,000.00 for every appearance in
court as evidenced by “Annex C”;

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 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) Sum of One Million Pesos (P1,000,000.00), plus interest at the rate

of Twelve Percent (12%) per annum as stipulated upon in the Promisory
Note;

b) Moral damages, exemplary damages, at the sound discretion of the

court;

c) Attorney’s fees amounting to P 75,000.00 plus Appearance Fee at

the rate of P 3,000.00 per court hearing/conference;

d) Litigation expenses.

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

Makati City, Metro Manila, Philippines, January 25, 2020.

EIVAN CRAIG DIZON

Counsel for the Plaintiff.
CDE Building
Valeria St., Iloilo City

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REPUBLIC OF THE PHILIPPINES)
CITY OF MAKATI )SS.
X-----------------------------------------X

VERIFICATION AND CERTIFICATION

I, Eve Celeste Garcia, Fillipino, of legal age, single and a resident of

of 111 Libertad St., Sampaloc, Metro Manila, Philippines, after duly being
sworn to in accordance with law, hereby depose and say:

That I am the Petitioner of the above-entitled case; That I have

caused the preparation of the above Petition and I have read the same and
knows the contents thereof; That the allegations contained therein are true
and correct of my own personal knowledge.

That I further certify that: (a) I have not theretofore commenced any
action or filed any action or claim involving the same issue in any court,
tribunal or quasi-judicial agency and, to the best of my knowledge, no such
other pending action or claim is pending therein; ( b) If there is such other
pending action or claim, a complete statement of the present status thereof;
and (c) If I should thereafter learn that the same or similar action or claim
has been filed or is pending, I shall report that fact within five (5) days
therefrom to the court wherein the aforesaid complaint or initiatory pleading
has been filed.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 25th of January 2020, Makati City, Metro Manila, Philippines.

EVE CELESTE GARCIA

Affiant

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 SUBSCRIBED AND SWORN to before me, this 25th day of January
2009 at Makati City, Metro Manila, Philippines, affiant having exhibited to
me his TIN bearing No. 01-426-257-951 issued on June 3, 2008 at Metro
Manila, Philippines.

ATTY. MAYREN P. ABUCION

Notary Public
Until December 31, 2010
PTR No. 1234567
IBP No. 58637
Roll No. 123456

Doc. No. ___

Page No. ___
Book No. ___
Series of 2009