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    Sample Complaint

    Uploaded by

    Igi Filoteo
    Ronald filed a complaint against Arnold in Cebu City Regional Trial Court Branch 66 for collection of a PHP 500,000 loan, damages, and attorney's fees. According to the complaint, Ronald loaned Arnold PHP 500,000 on February 14, 2000 that was due in one year. Arnold did not pay upon maturity of the loan and refused payment, insisting on a one-year extension. Despite repeated demands, Arnold still refused to pay. As a result, Ronald incurred PHP 200,000 in litigation expenses and PHP 50,000 in attorney's fees to pursue the case. Ronald is requesting the court to order Arnold to pay the PHP 500,000 loan, PHP 200,000 in damages, and PHP 50,000 in

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Sample Complaint

    Uploaded by

    Igi Filoteo
    329 views5 pages
    Ronald filed a complaint against Arnold in Cebu City Regional Trial Court Branch 66 for collection of a PHP 500,000 loan, damages, and attorney's fees. According to the complaint, Ronald loaned Arnold PHP 500,000 on February 14, 2000 that was due in one year. Arnold did not pay upon maturity of the loan and refused payment, insisting on a one-year extension. Despite repeated demands, Arnold still refused to pay. As a result, Ronald incurred PHP 200,000 in litigation expenses and PHP 50,000 in attorney's fees to pursue the case. Ronald is requesting the court to order Arnold to pay the PHP 500,000 loan, PHP 200,000 in damages, and PHP 50,000 in

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    Ronald filed a complaint against Arnold in Cebu City Regional Trial Court Branch 66 for collection of a PHP 500,000 loan, damages, and attorney's fees. According to the complaint, Ronald loaned Arnold PHP 500,000 on February 14, 2000 that was due in one year. Arnold did not pay upon maturity of the loan and refused payment, insisting on a one-year extension. Despite repeated demands, Arnold still refused to pay. As a result, Ronald incurred PHP 200,000 in litigation expenses and PHP 50,000 in attorney's fees to pursue the case. Ronald is requesting the court to order Arnold to pay the PHP 500,000 loan, PHP 200,000 in damages, and PHP 50,000 in

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    329 views5 pages

    Sample Complaint

    Uploaded by

    Igi Filoteo
    Ronald filed a complaint against Arnold in Cebu City Regional Trial Court Branch 66 for collection of a PHP 500,000 loan, damages, and attorney's fees. According to the complaint, Ronald loaned Arnold PHP 500,000 on February 14, 2000 that was due in one year. Arnold did not pay upon maturity of the loan and refused payment, insisting on a one-year extension. Despite repeated demands, Arnold still refused to pay. As a result, Ronald incurred PHP 200,000 in litigation expenses and PHP 50,000 in attorney's fees to pursue the case. Ronald is requesting the court to order Arnold to pay the PHP 500,000 loan, PHP 200,000 in damages, and PHP 50,000 in

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 5

    Republic of the Philippines

    REGIONAL TRIAL COURT


    7th Judicial Region
    Branch 66
    Cebu City
    RONALD, plaintif
    FOR: COLLECTION OF SUM OF
    MONEY,
    DAMAGES
    and
    ATTORNEYS FEES
    - versus -

    ARNOLD, defendant
    x----------------------------------/
    AMENDED PETITION/COMPLAINT
    COME NOW PLAINTIFF RONALD, thru the undersigned
    counsel, unto the Honorable Court respectfully avers, that:
    I
    Parties to the case
    1. Plaintif Ronald is a Filipino of legal age, married to
    Roma Mae and a resident of Barangay Lawaan II,
    Talisay City, Cebu, Philippines;
    2. Defendant Arnold is likewise a Filipino of legal age,
    married to Jenniveve and a resident of Barangay Tisa,
    Cebu City, Cebu, Philippines.

    II

    RONALD vs. ARNOLD

    Complaint

    Statement of Ultimate Facts

    Page 2 of 5

    x - - - - - - - - - - - - - - - - - - - -/

    1. On February 14, 2000,


    the defendant borrowed
    money from the plaintif amounting to FIVE
    HUNDRED THOUSAND PESOS (PHP 500,000.00)
    payable within a period of one year;
    2. Plaintif granted the said loan and gave the
    defendant FIVE HUNDRED THOUSAND PESOS;
    3. Plaintif asked defendant to execute and sign a
    promissory note specifying the amount loaned and
    the one-year maturity date;
    4. Upon the maturity of the loan and Plaintifs demand,
    Defendant was not able to pay the said loan;
    5. Defendant Arnold refused to pay the said loan and
    insisted that he be given a period of one-year to
    settle the same by reason of his upcoming Silver
    Wedding Anniversary;
    6. In view of the Arnolds refusal to settle his
    indebtedness, Plaintif caused his lawyer to send a
    demand letter requesting for the settlement of
    Defendant Arnolds indebtedness in the amount of
    FIVE HUNDRED THOUSAND PESOS (PHP
    500,000.00) within ten (10) days upon receipt
    thereof;
    7. In spite of repeated written and oral demands made
    by Plaintif Roland, Defendant Arnold ignored the
    same and still refused to settle his indebtedness;
    Damages
    8. Due to the refusal of the Defendant to settle his
    indebtedness despite repeated written and oral
    demands, herein Plaintif was made to incur litigation
    expenses in the amount of TWO HUNDRED
    THOUSAND PESOS (PHP 200,000.00), which
    includes the filing fees, court fees and other litigation
    expenses;

    RONALD vs. ARNOLD

    Complaint

    9. So as to prosecute the
    present case, herein
    x - - - - - - - - - - - - - - - - - - - -/
    Plaintif was constrained
    to secure the services of
    a lawyer and was made
    to pay the amount of FIFTY THOUSAND PESOS
    (PHP 50,000.00) and obligated himself to pay his
    counsel FIVE THOUSAND PESOS (PHP 5,000.00)
    per hearing;
    Page 3 of 5

    III
    PRAYER

    RONALD vs. ARNOLD

    Complaint
    Page 4 of 5

    x - - - - - - - - - - - - - - - - - - - -/

    WHEREFORE, it is respectfully
    prayed that,

    1. After trial, that an order be issued for the payment of


    the entire debt of FIVE HUNDRED THOUSAND
    PESOS (PHP 500,000.00).
    2. After trial, that an order be issued ordering the
    defendant to reimburse pay the plaintif the amount
    of PHP 200,000.00 as actual damages incurred by
    the plaintif in pursuing the present case, which is
    composed of the various litigation expenses and
    court fees;
    3. After trial, that an order be issued ordering the
    defendant to reimburse plaintif the amount of PHP
    50,000.00 and per appearance fee of PHP
    2,500.00 per hearing that plaintif incurred and will
    incur for the legal services needed in pursuing the
    present case.
    Plaintif prays for such other relief that is just and
    reasonable under the premises.
    Cebu City, Philippines. February 25, 2015.

    HENRY MIGUEL LUIGI T. FILOTEO


    Counsel for the Plaintif
    Roll No. 44949
    MCLE Compliance Certificate No. IV-1234567
    PTR No. 1938715, 1/07/15, B.C.
    IBP Lifetime No. 659241
    ANGEL LOCSIN FILOTEO LAW OFFICE
    Rm. 205, 2nd Floor, OngHoc Bldg.
    Banilad, Cebu City

    VERIFICATION & CERTIFICATE OF NON-FORUM


    SHOPPING

    RONALD vs. ARNOLD

    Complaint

    I, ROLAND, Filipino of legal


    age, and a resident of Barangay
    x - - - - - - - - - - - - - - - - - - - -/
    Lawaan II, Talisay City, Cebu,
    Philippines, after having sworn to
    in accordance with law, hereby
    depose and say:
    Page 5 of 5

    1.
    2.
    3.

    4.

    5.

    6.

    That I am the plaintif in the present case for


    For the Collection of Sum of Money, Damages,
    Attorneys Fees;
    That I have caused the preparation and filing of
    the foregoing amended complaint/petition;
    that I have read the allegations in the amended
    complaint/petition and the same are all true and
    correct based on my personal knowledge and
    upon authentic records and documents;
    That I have not commenced any other action
    involving the same issues in the Supreme Court,
    Court of Appeals or diferent divisions thereof, or
    any other tribunal or agency;
    No such action or proceeding is pending in the
    Supreme Court, the Court of Appeals, or diferent
    Divisions thereof, or any other tribunal or
    agency;
    That 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 diferent divisions thereof, or any other
    tribunal or agency, I undertake to promptly
    inform the aforesaid courts and other tribunal or
    agency thereof within five (5) days therefrom.

    IN WITNESS WHEREOF, I hereunto set my hand this


    25th day of February 2015 in the City of Cebu, Philippines.
    ROLAND
    CTC No.02356215
    Place of Issue Talisay City
    Date of Issue January 16, 2015
    SUBSCRIBED AND SWORN to before me this 25th day of
    February 2015 in the City of Cebu, Philippines.

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