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l Republic of the Philippines
5TH JUDICIAL REGION
Regional Trial Court
Branch 4
Legazpi City
RONNA M. NAZ, Civil Case No. 1524
Plaintiff FOR: COLLECTION OF
SUM OF MONEY WITH
DAMAGES
- versus -
SIONY M. CHUA,
Defendant
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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
Barangay East Washington, Legazpi City, Philippines while the defendant is
also of legal age, married, Filipino and a resident of Barangay Bitano, Legazpi
City, Philippines where summons and court processes may be served;
2. That on May 4, 2019, the defendant borrowed from the plaintiff
a sum of money amounting to Five Hundred Thousand Pesos(Php 500,000.00)
with an agreed interest of five percent (5%) per month as evidenced by a
promissory note herein attached as Annex “A” and form an integral part of
this complaint;
3. The indebtedness of the defendant has become due and
demandable on May 4, 2020, as shown in the attached promissory note;
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 the continued damage and prejudice of plaintiff, as
evidenced by Annex “B” – Demand Letters;
5. That the plaintiff has suffered moral damages at the sum
discretion of the Honorable Court;
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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 Five Hundred Thousand Pesos (PhP 500,000.00) 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. costs of this suit.
Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.
Legazpi City, December 6, 2020.
Aaron M. Mangampo
ATTY. AARON M. MANGAMPO
Counsel for Petitioner
Mangampo Law Office, Rawis, Legazpi City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/20, Legazpi City
IBP NO. 123456, 01/04/14, Legazpi City
MCLE Comp. No. IV-0009876, 01/02/20
Email address: mangampolaw@gmail.com
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REPUBLIC OF THE PHILIPPINES)
CITY OF LEGAZPI) SS.
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VERIFICATION AND CERTIFICATION
I, RONNA M. NAZ, of legal age, Filipino, married, and a resident of
Barangay East Washington, Legazpi City, Philippines, after being sworn in
accordance with law, hereby depose and say:
(1) That I am the Plaintiff in the above-entitled case;
(2) That I have caused the preparation of the above Complaint
and I have read the same and understood the contents thereof;
(3) That the allegations contained therein are true and correct
of my own personal knowledge and based on authentic records.
(4) That I further certify that: I have not theretofore
commenced any other action or proceeding or filed any claim involving
the same issues or matter in any court, tribunal, or quasi-judicial agency
and, to the best of my knowledge, no such action or proceeding is
pending therein; if I should thereafter learn that the same or similar
action or proceeding has been filed or is pending before the Supreme
Court, the Court of Appeals, or any other tribunal or quasi-judicial
agency, I undertake to report such fact within five (5) days therefrom
to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 6th day
of December 2020 at Legazpi City, Philippines.
R.M. Naz
RONNA M. NAZ
Affiant
PRC ID: 585487; Legazpi City
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SUBSCRIBED AND SWORN to before me, this 6th day of December
2020, affiant exhibiting to me his Professional Regulation Commission
Identification Card as shown above below his name as competent evidence of
his identity.
Aaron M. Mangampo
ATTY. AARON M. MANGAMPO
My Commission No. is 64
Expires on December 31, 2021
Mangampo Law Office, Rawis, Legazpi City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/20, Legazpi City
IBP NO. 123456, 01/04/14, Legazpi City
MCLE Comp. No. IV-0009876, 01/02/20
Email address: mangampolaw@gmail.com
Doc. No. 6;
Page No. 3;
Book No. 1;
Series of 2020;
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Annex “A”
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Annex “B”
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