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Republic of The Philippines Regional Trial Court National Capital Judicial Region Branch 100, Makati City

1. Plaintiff Forbes Fayvsic filed a civil case against Defendant Juan Tutri in the Regional Trial Court of Makati City for collection of money. 2. On February 14, 2018, Defendant obtained a loan of 500,000 pesos from Plaintiff, as evidenced by a promissory note. 3. The loan became due on February 14, 2019 but Defendant failed to pay despite demands, so Plaintiff is suing to collect the principal, interest, late fees, attorney's fees and moral damages.

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55 views3 pages

Republic of The Philippines Regional Trial Court National Capital Judicial Region Branch 100, Makati City

1. Plaintiff Forbes Fayvsic filed a civil case against Defendant Juan Tutri in the Regional Trial Court of Makati City for collection of money. 2. On February 14, 2018, Defendant obtained a loan of 500,000 pesos from Plaintiff, as evidenced by a promissory note. 3. The loan became due on February 14, 2019 but Defendant failed to pay despite demands, so Plaintiff is suing to collect the principal, interest, late fees, attorney's fees and moral damages.

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Pu Pujalte
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


National Capital Judicial Region
Branch 100, Makati City

Forbes Fayvsic, Plaintiff,

-versus-

CIVIL CASE No. 000001

FOR: COLLECTION OF
SUM OF MONEY
Juan Tutri, Defendant.

x------------------------------------------------------------x

COMPLAINT

Plaintiff, through counsel, and unto this Honorable Court respectfully


states that:

1. Plaintiff is of legal age, single, Filipino, and resident of Unit 10D,


One Rockwell - East Tower, Rockwell Drive, Makati City, Metro
Manila where summons and court processes may be served;

2. Defendant is also of legal age, single, Filipino, and resident of 20,


Mercedes St., Bel-Air, Makati City, Metro Manila where summons and
court processes may be served;

3. On 14 February 2018, Defendant obtained a loan from Plaintiff in


the amount of Five Hundred Thousand Pesos (P500,000.00), as
evidenced by a PROMISSORY NOTE, a photocopy of which is
attached as “Annex A” and made an integral part of this complaint;

4. As shown in the attached promissory note, the indebtedness of the


Defendant has become due and demandable on 14 February 2019;
5. Despite the repeated demands of the Plaintiff both verbal and
written, the Defendant failed, and still refuses to comply with his
obligation to settle and pay the said amount.

6. That Defendant has in fact received the written letter of demand on


19 February 2019. As evidenced by the annexed documents bearing
his signature. The photocopies of Plaintiff’s demand letters are
attached as “Annex B”, and “Annex C”;

7. The said loan is now long overdue, thus, in order to protect and
enforce his rights, Plaintiff has sought the services of a legal counsel
and thus incurred Attorney's Fees in the amount of Fifty Thousand
Pesos (P50,000.00), and litigation expenses in the amount of Five
Thousand Pesos (P5,000.00).

PRAYER

WHEREFORE, premises considered, it is respectfully prayed before


the Honorable Court to render a decision in favor of the Plaintiff and
to order the Defendant to pay:

1. The amount of FIVE HUNDRED THOUSAND PESOS


(P500,000.00), representing the Principal amount promised to pay
and due under the Promissory Note dated 30 January 2017;

2. The amount of SIXTY-FIVE THOUSAND PESOS (P65,000.00),


representing the Interest due under the Promissory Note dated 14
February 2018;

3. The amount of FIVE THOUSAND SIX HUNDRED AND FIFTY


PESOS (P5,650.00), representing the Late Charge amount as based
on the agreed 1% of the amount payable for every month of delay or
fraction thereof under the Promissory Note dated 14 February 2019;

4. The amount of FIFTY THOUSAND PESOS (P50,000.00),


representing the Attorney’s Fees incurred by the Plaintiff;

5. The sum of FIVE THOUSAND PESOS (P5,000.00), as and by way


of Moral Damages;

6. Cost of suit.
Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

Makati City, Philippines, February, 2018.

Bettina Castelo
Counsel for Plaintiff
CGPV Law Office
Block 33, University
Parkway, Taguig City,
Metro Manila
Roll of Attorneys No.
56789
PTR No. 123654,
1/6/2018
IBP No. 789654,
1/6/2018
MCLE Compliance No.
V-009878, 1/2/2018

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