Republic of The Philippines 6 Judicial Region Regional Trial Court Iloilo City Branch

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Republic of the Philippines

6th JUDICIAL REGION
Regional Trial Court
IloIlo City
Branch ___
JENICA ALEXIS C. CANLAS,

Plaintiff,
-versus- Civil Case No.___

For: Collection for a
Sum of money with
damages
RONELLE F. GALANG,
Defendant,
x--------------------------------------x
COMPLAINT
Plaintiff, through the undersigned counsel unto this Honorable Court, hereby
respectfully avers:
1. That plaintiff is of legal age, Filipino, married, and a resident of Samson Village,
Jaro, IloIlo City, ehile defendant is also of legal age, married, Filipino and a
resident of Brgy. Dungon A, Jaro, IloIlo City where summoned processes may be
served.
2. That on February 14,2013 the defendant borrowed from the plaintiff the sum of
money amounting to Two Million Pesos (P2,000,000.00) with an agreed interest
of five (5%) per month as evidenced by a promissory note herein attached as
Annex “A” and form an integral part of this complaint;
3. That as shown in the attached promissory note, the indebtedness of the

defendant has become due and demandable on February 14,2014;
4. That despite plaintiff’s repeated demands, both written and verbal, defendant
failed, neglected and refused to fulfill obligations without just and valid grounds to
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the continued damage and prejudice of plaintiff, as evidenced by Annex “B”

Demand Letter;
5. That the plaintiff in order his rights and interests, has sought the services of a
legal counsel with attorney’s fees amounting to Two Hundred Thousand pesos
(P200,000.00) and an appearance fee of Four Thousand Pesos (P4,000.00) per
hearing as evidenced by Annex “C” Contract for Legal Services;
6. That the plaintiff has paid for litigation expenses amounting to Forty Thousand
Pesos (P40, 000.00) as evidenced by Annex “D” Official Receipt.
7. That the plaintiff has suffered moral damages at the sum discretion of the
Honorable Court.
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. The sum of Two Million Pesos (P2, 000,000.00) plus interest at the rate of five
percent (5%) per month as stipulated in the promissory note.
b. Moral damages, exemplary damages at the sum discretion of the court;
c. Attorney’s fees amounting to Two Hundred Thousand Pesos (P200,000.00) and

an appearance fee of Four Thousand Pesos (P4,000.00) per hearing;
d. Litigation expenses amounting to Forty Thousand Pesos (P40,000.00);
Other reliefs and remedies deemed just and equitable under the foregoing premises
are likewise prayed for.
Iloilo City, December 6, 2014.
Atty. Edward Sanchez

Commission Serial No. 14786
Until December 31, 2014
Roll of Attorney 78956
IBP No. 547698/January 1, 2014/ Manila
P.T.R No. 546468/ January 1, 2014
Roll No. 2256
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VERIFICATION AND CERTIFICATION
I, JENICA ALEXIS C. CANLAS, of legal age, Filipino, married, and a resident of

Brgy. Dungon, Jaro, IloIlo City, after being sworn in accordance with law, hereby
depose and say:
1. That I am the plaintiff in the foregoing case and that I have caused the
preparation of the above Complaint;
2. That I attest to the truth of all allegations in the same petition of my own personal
knowledge;
3. That I hereby certify under oath that I have not heretofore commenced any other
action or proceeding involving the same issues in the Supreme Court, Court of
Appeals, or any other tribunal or agency, and that to the best of my knowledge,
there is no pending before this Honorable Court, Court of Appeals, Supreme
Court or any other tribunal or agency involving the same parties and the same
issues, and that if I learn hereafter that there are other proceedings pending
before this Honorable Court, or any other tribunal or agency, I hereby undertake
to report that fact within five (5) days therefrom to this Honorable Court.
IN WITNESS WHEREOF, I have hereunto set my hand this 6th day of December
2014 at IloIlo City, Philippines.
JENICA ALEXIS C. CANLAS

Affiant
TIN 12345-6789; IloIlo City
SUBSCRIBED AND SWORN to before me, this 6th day of December 2014, affiant
exhibiting to me Tax Identification Card as shown above below his name as competent
evidence of his identity.
Doc No____:
Page No___:
Book No____:
Series of 2014 NOTARY PUBLIC

Republic of The Philippines 6 Judicial Region Regional Trial Court Iloilo City Branch

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Republic of the Philippines

JENICA ALEXIS C. CANLAS,

-versus- Civil Case No.___

3. That as shown in the attached promissory note, the indebtedness of the

the continued damage and prejudice of plaintiff, as evidenced by Annex “B”

WHEREFORE, premises considered, it is hereby respectfully prayed before the

b. Moral damages, exemplary damages at the sum discretion of the court;

c. Attorney’s fees amounting to Two Hundred Thousand Pesos (P200,000.00) and

d. Litigation expenses amounting to Forty Thousand Pesos (P40,000.00);

Iloilo City, December 6, 2014.

Atty. Edward Sanchez

VERIFICATION AND CERTIFICATION

I, JENICA ALEXIS C. CANLAS, of legal age, Filipino, married, and a resident of

JENICA ALEXIS C. CANLAS

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