Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch ____
Davao City

CAMILA DELA CUESTA Civil Case No. _____

Plaintiff. FOR: COLLECTION
FOR A SUM OF
- versus - MONEY

JUAN DELA CRUZ

Defendant.
x ---------------------------- x

COMPLAINT

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

1. That plaintiff CAMILA DELA CUESTA is of legal age and a resident

of Ladislawa Village, Buhangin, Davao City while defendant JUAN
DELA CRUZ is likewise of legal age and a resident of Apokon, Tagum
City;

2. That on January 1, 2018, defendant borrowed from plaintiff the sum of

five hundred thousand pesos (P500,000), which indebtedness was to be
paid and to earn interest in accordance with the terms of a promissory
note which was executed by defendant on the same date, which
instrument is copied verbatim, hereunder:

“For value received, I promise to pay Mrs. Camila dela Cuesta

the sum of five hundred thousand pesos (P500,000), on or before
December 30, 2018, plus interest at the rate of 5% per month.

Davao City, Philippines

January 1, 2018 (sgd.) Juan dela Cruz

3. That the payment of said indebtedness is now overdue, and defendant

has failed and refused, and still fails and refuses, to pay the same,
notwithstanding repeated demands from plaintiff;

4. That defendant likewise failed to pay any interest due on the

aforementioned obligation.
 PRAYER

WHEREFORE, it is respectfully prayed that judgment be issued in favor of

plaintiff and against defendant, ordering the latter:

1. To pay to plaintiff the sum of five hundred thousand pesos (P500,000),

plus interest thereon at the rate of 5% per month from February 1, 2018
until complete payment is made;

2. To pay attorney’s fees and other costs of litigation;

3. Other equitable reliefs as may be deemed just.

Davao City, Philippines. August 29, 2019.

ATTY. KRISTIAN WELLER P. LICUP

Counsel for the Plaintiff
XYZ Law Office, Davao City
PTR No. 7777777
IBP OR No. 777777
Roll No. 7777
MCLE Cert. No. 7777777
+63 917 7042520
Bordge918@gmail.com

VERIFICATION AND CERTIFICATE

OF NON-FORUM SHOPPING

Republic of the Philippines)

City of Davao . . . . . . . . ..) S. S.

I, CAMILA DELA CUESTA, of legal age, residing at Ladislawa Village,

Davao City, after being sworn to in accordance with law, depose and say:

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

2. That I have caused the preparation of the foregoing complaint for

collection of sum of money before the Honorable Regional Trial
Court;

3. That the facts stated in the above complaint are true and correct to the
best of my knowledge, belief and authentic records;
 4. That I have not commenced any action or filed any claim involving
the same issues in any court, tribunal or quasi-judicial agency and, to
the best of my knowledge, no such other action or claim is pending in
them; and

5. That if I should thereafter learn that the same or similar action or

claim has been filed or is pending, I shall promptly report that fact
within five (5) days from notice to the court or where the complaint or
initiatory pleading has been filed.

Davao City, Philippines. August 29, 2019.

CAMILA DELA CUESTA

Affiant

JURAT

SUBSCRIBED AND SWORN to before me this 29th day of August 2019 in

the city of Davao Philippines. Affiant exhibiting to me her Unified Multi-
Purpose ID 007-1234567-7 issued in Davao City on September 18, 2007,
bearing her photograph and signature, known to me as the same person who
personally signed the foregoing instrument before me and avowed under
penalty of law to the whole truth of the contents of said instrument.

ATTY. KRISTIAN WELLER P. LICUP

Notary Public
Commission Serial No. 77777
Until December 31, 2019
PTR No. 7777777
IBP OR No. 777777
Roll No. 7777
MCLE Cert. No. 7777777
+63 917 7042520
Bordge918@gmail.com

Doc No. ___;

Page No. ___;
Book No ___;
Series of 2019.