Complaint Gloria Ong

REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT, MANILA
Branch ____
GLORIA UY ONG,
Plaintiff,
- versus - CRIMINAL CASE NO. __________

Violation of BP.22
MR. ROGELIO SY,
Defendant.
x--------------------------------------------x
C O M P LA I N T
Plaintiff through the undersigned counsel and unto this Honorable Court, most
respectfully states:
1. Plaintiff GLORIA UY ONG, of legal age, Filipino and a resident of
____________________________________________________. For purposes of this
action, plaintiff may be served with all orders, notices and other processes of this
Honorable Court through the office address of the undersigned counsel indicated
below;
2. Defendant MR. ROGELIO SY, of legal age, Filipino and with postal address at 1180
Masangkay St. Rm. 301 Binondo, Manila and may be served with summons and other
processes of this Honorable Court at their said address;
3. That defendant issued post-dated checks in exchange of cash in the amount of NINE
HUNDRED THIRTY EIGHT THOUSAND AND SEVEN HUNDRED THIRTY
ONE PESOS (P938,731.00) Philippine Currency;
4. That Defendants has failed and neglected to pay, without just and valid grounds the
said obligation;
5. That despite Plaintiff’s repeated demand, both written and verbal, Defendants failed,
neglected and refused to pay and settle his outstanding obligation;
6. That plaintiff made a final demand upon the defendant to pay the said obligations
within five (5) days upon receipt thereof, otherwise, legal action would be taken
against him, copy of said Demand Letter is hereto attached and marked as Annex
“A”;
7. That despite receipt of the letter and more than five (5) days had elapsed, the
defendant failed and refused to pay his outstanding obligation;
8. That in view of the unwarranted refusal and failure of defendant, herein plaintiff was
constrained to seek the services of Counsel to prosecute its claim in court against
defendant at an agreed contingent Attorney’s fees of P20,000.00 plus P2,000.00 per
daily court appearance;
WHEREFORE, after due notice and hearing, Plaintiff respectfully prays that judgment be
rendered against the Defendant as follows:
1. Defendants to pay the principal amount of P 134,500.00 plus interest of 5% monthly

interest;
2. Defendants to pay P 20,000.00 for Attorney’s fee and P 2,000.00 per daily court
appearance;
3. Cost of suit.
Other relief and remedies as may be just and equitable is likewise prayed for.
Manila, Philippines.
February 16, 2007.
AMANDO M. TETANGCO
Counsel for Plaintiff
1048 Ilaya St., Tondo, Mla.
PTR No. 5309584 1-2-07
IBP No. 667243 12-31-07
Atty.’s Roll 19459
Manila
Branch Clerk of Court

Metropolitan Trial Court
Branch ___
GREETINGS:
Kindly submit the foregoing Complaint unto this Honorable Court.
AMANDO M. TETANGCO
COPY FURNISHED :
MR. ARIEL M. BARTOLOME and

M/S. GEORGINA M. BARTOLOME
Balanga, Bataan
REPUBLIC OF THE PHILIPPINES )
IN THE CITY OF MANILA……… )
VE R I FI CAT I O N
I, ADELFA ROMERO, of legal age, Filipino and a resident of 1015 Sto. Cristo St. Tondo,
Manila, after having been duly sworn to in accordance with law, hereby depose and say:
1. That I am the Plaintiff in the above Complaint;
2. That I caused the preparation of this foregoing Complaint;
3. That I have read the contents thereof, and all the allegations contained therein are true
and correct of my own knowledge;
4. That I hereby certify the truth of the foregoing facts and undertakings;
5. That neither nor counsel hereof have commenced any other motions or proceedings
involving the same issues in the Supreme Court, the Court of Appeals, or any other tribunal or
agency. That if I should hereafter 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 hereby
undertake to report such fact to this Honorable Court within five (5) days from notice.
ADELFA ROMERO
Affiant
SUBSCRIBED AND SWORN to before me this 16th day of February, 2007 in the City
of Manila, Philippines. Affiant exhibited to her CTC No. ____________ issued on ________ at
MANILA.
Doc. No. 450; AMANDO M. TETANGCO

Page No. 90; NOTARY PUBLIC
Book No. 103; UNTIL DECEMBER 31, 2007
Series of 2005. PTR NO. 5309584
January 2, 2007
MANILA

Complaint Gloria Ong

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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

- versus - CRIMINAL CASE NO. __________

1. Plaintiff GLORIA UY ONG, of legal age, Filipino and a resident of

____________________________________________________. For purposes of this

processes of this Honorable Court at their said address;

HUNDRED THIRTY EIGHT THOUSAND AND SEVEN HUNDRED THIRTY

ONE PESOS (P938,731.00) Philippine Currency;

neglected and refused to pay and settle his outstanding obligation;

defendant failed and refused to pay his outstanding obligation;

defendant at an agreed contingent Attorney’s fees of P20,000.00 plus P2,000.00 per

daily court appearance;

rendered against the Defendant as follows:

1. Defendants to pay the principal amount of P 134,500.00 plus interest of 5% monthly

Branch Clerk of Court

Kindly submit the foregoing Complaint unto this Honorable Court.

MR. ARIEL M. BARTOLOME and

Doc. No. 450; AMANDO M. TETANGCO

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