Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

Sepha Pagdanganan,

Plaintiff,

-versus-

Angelo Santiago,

Defendant.

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

Civil Case No 123456

FOR: _____________________________

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipina, of legal age, and resident of 6750 Dasmarinas
Village, Makati City; defendant is a Filipino, of legal age and resident of 6752,
Jupiter City Makati City, where he may be served with summons and other
processes.
2. Sometime in February 2021 and over a period of four (4) months,
defendant borrowed certain amounts from plaintiff. Defendant promised to pay
these amounts on an installment basis monthly. These amounts now total
Nine Hundred Thousand Pesos (P900,000.00).
3. Despite repeated demands, both oral and written, defendant failed or
has refused to pay any amount to plaintiff as no installment payment has even
been made. A copy each of plaintiff’s two (2) demand letters is attached as
ANNEX A and B.
4. Resort to the Barangay Conciliation process proved fruitless as
defendant failed to appear, despite notice on him to appear. Thus, a
Certification to File Action, a copy of which is attached as ANNEX C, was
issued by the Barangay Chairman.
5. Defendant’s obligation is due and demandable and plaintiff is entitled to
the payment of the entire amount of Nine Hundred Thousand Pesos
(P900,000.00) plus legal interest.
6. By reason of defendant’s unreasonable failure or refusal to pay his due
and demandable obligation, plaintiff was forced to engage the services of
counsel to vindicate his rights thereby committing himself to pay legal
expenses amounting to Fifty Thousand Pesos (P50,000.00).

WHEREFORE, plaintiff respectfully prays for judgment in his favor through a

Decision directing defendant to pay him NINE HUNDRED THOUSAND
PESOS (P900,000.00), with legal interest, as ACTUAL DAMAGES and FIFTY
THOUSAND PESOS (P50,000.00) as Attorney’s Fees.

Other just and equitable reliefs are also prayed for.

Quezon City for Makati; 13 April 2007.

(Sgd.) Stephanie Pagdanganan

Counsel for Plaintiff

Republic of the Philippines

MUNICIPAL TRIAL COURT

Muntinlupa City

SEPHA PAGDANGANAN

Plaintiff,

Civil Case No. 55121

For: Unlawful Detainer

ANGELO SANTIAGO

Respondent.

x-------------------------------x
COMPLAINT

PLAINTIFF, by counsel, and unto this Honorable Court, most respectfully

allege: THAT

1. Plaintiff is of legal age, Filipino, with residence and postal address at 6

Don Martini, Alabang hills Village,, Muntinlupa City where she may be served
notices and other court processes;

2. Respondent is of legal age, Filipino, with residence and postal address at

1234 Apartments Rocker street, Muntinlupa City;

3. Plaintiff is the absolute owner and lessor of that certain apartment

situated in Muntinlupa City and now leased ad occupied by the respondent;

4. Pursuant to the lease contract (Exhibit A) executed by the plaintiff and

the respondent dated October 28, 2020, the respondent is obliged to pay a
monthly rental payment of P10,000.00 to the plaintiff;

5. A stipulation in the said lease contract provides that in case of default by

the lessee of the payment of the rent such as when the checks are
dishonored, the plaintiff at its option may terminate this contract and eject the
lessee;

6. On January 28, 20,21 the plaintiff tried to encash BPI Check No. 123455
corresponding to the rental payment for the month of January but the same
was dishonored due to insufficiency of funds;

7. On the same day, plaintiff informed the respondent that the latter’s check
was dishonored and demanded that formed be paid in cash instead but the
respondent failed to do so;
8. On February 28, 2016, the plaintiff tried to encash BPI Check No. 25614
corresponding to the rental payment for the month of February but the same
was also dishonored due to insufficiency of funds;

9. On the same day, plaintiff again went to the respondent and demanded
for the payment of the two dishonored checks and for respondent to vacate
the premises but respondent failed to tender payment and refused to vacate
the premises;

10. On March 15 2021 , plaintiff, with assistance of a counsel,

sent a formal demand letter (Exhibit B) to the respondent giving him ten days
to make his rental payment and vacate the premises

11. On March 25, 2 021, at the expiration of the ten-day grace

period given by the plaintiff, the respondent still has not made his payment
and consistently refused to vacate the apartments;

12. Until now, respondent still refuse to vacate and restore

possession and pay his rentals.

13. Thus, respondent is unlawfully withholding possession of

the subject apartment from the plaintiff despite last and final demand, to the
damage and prejudice of the plaintiff;

14. Before filing this complaint, the dispute has been referred
to the Lupong Tagapamayapa of Cavite City but the respondent failed to
appear, hence, no amicable settlement was made (Exhibit C).

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that after due notice and hearing, judgment be rendered in
favor of Plaintiff:

1. For the restitution of the abovementioned apartment;

2. For the payment of TWENTY THOUSAND PESOS (P20,000.00),
Philippine currency, representing the arrears of rent now overdue;

3. To pay the cost of the suit

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

Muntinlupa City, Philippines, March 31, 2021.

ATTY. NICHOLAS KROMANN

Counsel for Plaintiff

Kromann & Associates Law Firm

1234 Muntinlupa City

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines

(City of Muntinlupa ) S.S.

I, SEPHA PAGDANGANAN, of legal age, after having been duly sworn in

accordance with law, depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of documents
and records in my possession;

4. 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;

5. To the best of my knowledge and belief, no such action or proceeding is

pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;

6. If I should thereafter 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 that fact within five (5) days therefrom
to this Honorable Court.

Muntinlupa City, Philippines, March 31, 2016

__________________

Sepha Pagdanganan

SUBSCRIBED AND SWORN to before me this 31st day of March

2021 at Cavite City, Philippines affiant exhibiting to me her Passport No.
58158450 issued in DFA Manila 2014.

Doc. No.___________; Kayelyn Lat

Page No.___________; NOTARY PUBLIC for Cavite

Book No.__________; Commission Serial No.______

Series of 2016. Until December 31, 2016

Roll of Attorney_______

IBP No.________

PTR No._______

1. Complaint for Sum of Money

2. Specific Performance with Damages

3. Unlawful Detainer
4. Petition for Annulment of Marriage