MyLegalWhiz - Complaint For Sum of Money

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[Court]

[Region]
[COURT]
[City], [Branch No.]

[NAME]__________,
Plaintiff,
Civil Case No. ___________
- versus - For: Sum of Money

[NAME]__________,
Defendant.
x ----------------------------------- x

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a [NATIONALITY/CITIZENSHIP] ________________, of legal age, and


resident of [ADDRESS] _________________; defendant is a [NATIONALITY/CITIZENSHIP]
__________, of legal age and resident of [ADRESS] ____________________, where he may
be served with summons and other processes.

2. Sometime in January 2005 and over a period of six (6) 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 [AMOUNT IN PESOS IN BOTH LETTERS AND FIGURES]
_______________________ 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 [AMOUNT IN PESOS IN
BOTH LETTERS AND FIGURES] _________________________.

WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision
directing defendant to pay him [AMOUNT IN PESOS IN BOTH LETTERS AND FIGURES]
__________________ with legal interest, as ACTUAL DAMAGES and [AMOUNT IN PESOS IN
BOTH LETTERS AND FIGURES] ________________ as Attorney’s Fees.

Other just and equitable reliefs are also prayed for.

[CITY] __________; [DATE] ________________________.

[SIGNATURE]
[NAME] _______________
Counsel for Plaintiff
[ADRESS]

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

I, [NAME] _____________________, of legal age, do hereby state that: I am the


plaintiff in the pleading/document entitled [PLEADING/DOCUMENT BEING VERIFIED]
___________________ and in such capacity, caused this Complaint to be prepared; I have
read its contents and affirm that they are true and correct to the best of my own personal
knowledge; I hereby certify that there is no other case commenced or pending before any
court involving the same parties and the same issue and that, should I learn of such a case,
I shall notify the court within five (5) days from my notice.

IN WITNESS WHEREOF, I have signed this instrument on [DATE]_____________.

[SIGNATURE]
[NAME] _________________

SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day


of [MONTH AND YEAR]_________________, affiant exhibiting before me his Government
Issued ID no. _______________ issued on [DATE}__________________ at [PLACE OF
ISSUANCE]_____________________.

[SIGNATURE]
[NAME]_______
Notary Public

Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________

Doc. No.
Page No.
Book No.
Series of [YEAR] ___________.

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