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Republic of The Philippines National Capital Judicial Region Metropolitan Trial Court of Manila Manila, Branch

Plaintiff is suing Defendant for failing to pay back a 50,000 peso promissory note that was due 30 days after August 1, 1990. Despite demands for payment after the 30-day period elapsed, Defendant refused to pay. Plaintiff is requesting the court order Defendant to pay back the 50,000 pesos plus interest as actual damages, and 10,000 pesos in attorney's fees.

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Irene Balmes-Lomibao
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14K views2 pages

Republic of The Philippines National Capital Judicial Region Metropolitan Trial Court of Manila Manila, Branch

Plaintiff is suing Defendant for failing to pay back a 50,000 peso promissory note that was due 30 days after August 1, 1990. Despite demands for payment after the 30-day period elapsed, Defendant refused to pay. Plaintiff is requesting the court order Defendant to pay back the 50,000 pesos plus interest as actual damages, and 10,000 pesos in attorney's fees.

Uploaded by

Irene Balmes-Lomibao
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT OF MANILA
Manila, Branch __

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff ______________ (hereafter Plaintiff) is a Filipino citizen, of legal


age, married and residing at ____________________ where he may be served with
court processes, motions, and decision;

2. Defendant _______________ (hereafter Defendant) is a Filipino citizen,


of legal age, and residing _______________________________ where he may be
served with summons and other court processes;

3. That on August 1, 1990, defendant executed a promissory note in favor


of the plaintiff in the amount of P________ payable within 30 days from the date of the
promissory note (attached as “Annex A”) which reads as follows:

Manila, Philippines
1 August 1990

I promise to pay Juan dela Cruz the sum of P50,000 or order within
30 days from this date.
PEDRO REYES

4. That the 30-day period had elapsed and despite demands made orally
and in writing (attached as “Annex B”) by the plaintiff, defendant refused and failed to
pay the amount stated in the promissory note.

5. That due to the unjust refusal of defendant to comply with the demands,
plaintiff was compelled to file the instant action engaging the services of counsel in the
amount of P10,000.00.

PRAYER
WHEREFORE, plaintiff respectfully prays for judgment in his favor through a
Decision directing defendant to pay him FIFTY THOUSAND PESOS (P50,000.00), with
legal interest, as ACTUAL DAMAGES and TEN THOUSAND PESOS (P10,000.00) as
Attorney’s Fees.

Other just and equitable reliefs are also prayed for.

Place and date.

Signature of Counsel

[VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING]

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