Complaint Pleading - Edited

Republic of the Philippines
MUNICIPAL TRIAL COURTS IN CITIES

Branch _________
CJ Ramon Q. Avanceña Hall of Justice
Bonifacio Drive, Iloilo City
DINA N. NATUTO
Plaintiff, Civil Case No._______
- versus – For: Sum of Money

with damages
MANDA R. RAMBONG
Defendant
x----------------x
COMPLAINT
Plaintiff by the undersigned counsel, to this Honorable Court,

respectfully states that:
1. That plaintiff is of legal age, Filipino, married and resident of Brgy.

San Isidro, La Paz, Iloilo City;
2. That the defendant is likewise of legal age, Filipino, married and

resident of Guzman St., Passi City, where she may be served with summons
and other court processes;
3. Last December 1, 2015 Defendant Manda Rambong obtained a loan

from the plaintiff and executed a Promissory Note in favor of the latter’s office
at Gen. Luna St., La Paz, Iloilo City in the amount of TWO HUNDRED FORTY
THOUSAND PESOS and 00/100, Philippine currency (Php240,000.00) with
interest at the rate of twelve per cent (12%) per annum and payable in twenty-
four (24) monthly installments starting February 1, 2016 and payable every
first day of the succeeding months until fully paid in the amount of TWELVE
THOUSAND FOUR HUNDRED PESOS and 00/100, Philippine currency
(Php12,400.00) every month.
4. The defendant made the first three months of payments but

failed to pay thereafter. Since then, the defendant Manda Rambong has
continuously and intentionally failed to pay her account to the plaintiff, in the
amount of TWO HUNDRED SIXTY THOUSAND FOUR HUNDRED PESOS and
00/100, Philippine Currency, (Php260,400.00);
5. As provided in the Promissory Note Defendant Manda Rambong

executed, Defendant’s failure to pay any one of the installments when due shall
make the entire balance of the loan due and payable;
6. In view of the Defendant Manda Rambong’s failure to pay the monthly

installment of her loan, the whole amount of TWO HUNDRED SIXTY
1
THOUSAND FOUR HUNDRED PESOS and 00/100, Philippine Currency,
(Php260,400.00) has now become due and demandable;
7. Due to the failure of the Defendant to pay her loan obligation to the
plaintiff, Dina Natuto, sent her office assistant to Defendant’s residence several
times to demand and collect from her payment for her loan obligation; however,
despite several promises made by Defendant, she unjustifiably failed to do so;
In view thereof, the plaintiff was constrained to request her lawyer to send
formal demand letters to Defendant;
8. Said demand letter was received at the address where it was sent as
shown by the signature on the Return Card.
9. Despite receipt of the Last and Final Demand Letter sent by the
Plaintiff’s lawyer, Defendant Manda Rambong still intentionally and adamantly
refused and failed to pay her loan obligation to the Plaintiff, to the prejudice of
the latter, hence she was constrained to file the above case
10. Defendant’s unjustified refusal and failure to pay her loan obligation
make her liable to pay the Plaintiff the amount of TWO HUNDRED SIXTY
THOUSAND FOUR HUNDRED PESOS and 00/100, Philippine Currency,
(Php260,400.00);
11. The above case is not covered by the Katarungang Pambarangay Law.
WHEREFORE, it is respectfully prayed of this Honorable Court, after

hearing, to render a decision in favor of Plaintiff and as against Defendant,
ordering the latter:
a. To pay the Plaintiff the amount of TWO HUNDRED SIXTY

THOUSAND FOUR HUNDRED PESOS and 00/100, Philippine
Currency, (Php260,400.00)
b. To pay penalty charge as liquidated damages in an amount

equivalent to 2% per month on the total collectible amount plus
interest computed from the date of default on May 2, 2016 up
to the date of the filing of the above case; and
c. To pay attorney’s fees equivalent to 25% of the total collectible

amount plus interest as well as ligation fees and consequential
expenses incurred by the Plaintiff in the filing of the above case,
the amount of which shall be proven during the hearing of the
above case.
Plaintiff prays for such other reliefs as may be just and. proper under the
circumstances
Iloilo City, Philippines, February 13, 2021
ANTONIE C. COLLANTES
Counsel for Plaintiff
2
196 General Luna Street
La Paz, Iloilo City
PTR No. 6258697/ 1-5-2021
IBP Rcpt. No. 2365854/ 1-5-2021
All Issued at Iloilo City
Roll No. 654789
MCLE Compliance No. V-00669958
Issued on January 15, 2020
At Pasig City, Philippines
VERIFICATION AND CERTIFICATION

I, DINA N. NATUTO, Filipino, of legal age, married and resident of Brgy.
San Isidro, La Paz, Iloilo City, after having been sworn to in accordance with
law, depose and say:
That I am the plaintiff in the above-entitled case;
That I caused the preparation of the foregoing Complaint, and that I have
read the contents thereof and the facts stated therein are true and correct
based on my own personal knowledge and/or existing authentic records;
That I further certify under oath that I have not heretofore commenced
any other action or proceeding against the defendant involving the same issues
and in the Supreme Court, the Court of Appeals, or any tribunal or agency;
That to the best of my knowledge, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any tribunal or agency;
That if there is such other action or proceeding pending, I must state the
status of the same;
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 any
tribunal or agency, I undertake to promptly report the fact within 5 days
therefrom to the court or agency where the original pleading and Sworn
Certification contemplated therein have been filed.
IN WITNESS WHEREOF, I have hereunto set my hand in the City of
Iloilo, Philippine, this 13th day of February 2021.
DINA N. NATUTO
Affiant
Sr. Citizen ID No. 16891
Issued on December 15, 2018
Issued at Iloilo City
SUBSCRIBED AND SWORN TO, before me this 13th day of February

2021 in the City if Iloilo, Philippines, affiant have appeared in person before me
3
and present the foregoing Verification and Certificate of Non-ForumA Shopping,
signed the same in my presence and affirmed/swore under oath to the
correctness of the contents or allegations of the same. The affiant is personally
known to me and had exhibited to me his competent evidence of identity
bearing his name, signature and photograph.
NINO T. TARYOCO
Notary Public
For the Province/City of Iloilo
Until December 31, 2021
Commission Register No. 85
Iloilo City, May 15, 2020
196 General Luna Street
La Paz, Iloilo City
PTR No. 566658/ 1-5-2021
IBP Rcpt. No. 1122569/ 1-5-2021
Doc. No. 54; All Issued at Iloilo City
Page No. 15; Roll No. 547896
Book No. XXIV MCLE Compliance No. V-00781958
Series of 2020 Issued on January 15, 2020
At Pasig City, Philippines

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Republic of the Philippines

MUNICIPAL TRIAL COURTS IN CITIES

- versus – For: Sum of Money

Plaintiff by the undersigned counsel, to this Honorable Court,

1. That plaintiff is of legal age, Filipino, married and resident of Brgy.

2. That the defendant is likewise of legal age, Filipino, married and

3. Last December 1, 2015 Defendant Manda Rambong obtained a loan

4. The defendant made the first three months of payments but

5. As provided in the Promissory Note Defendant Manda Rambong

6. In view of the Defendant Manda Rambong’s failure to pay the monthly

WHEREFORE, it is respectfully prayed of this Honorable Court, after

a. To pay the Plaintiff the amount of TWO HUNDRED SIXTY

b. To pay penalty charge as liquidated damages in an amount

c. To pay attorney’s fees equivalent to 25% of the total collectible

Iloilo City, Philippines, February 13, 2021

VERIFICATION AND CERTIFICATION

SUBSCRIBED AND SWORN TO, before me this 13th day of February

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