(Uy - G04) Seatwork 1 Complaint For Sum of Money

Republic of the Philippines
Regional Trial Court

National Capital Judicial Region
Branch 79, Quezon City
Josefina Ramos,
Plaintiff,
Civil Case No.
- versus - For: Sum of Money
Marie Carlos and Diego Carlos,

Defendant.
x ----------------------------------- x
COMPLAINT
PLAINTIFF, by counsel, respectfully states that:
1. Plaintiff is a Filipino, of legal age, and resident of 1598

Scout Fuentebella, Timog, Quezon City; defendant is a Filipino, of
legal age, married to Diego Carlos, and resident of 689 Brentwood
Street, Brookside Hills, Cainta, Rizal, where he may be served with
summons and other processes.
2. On January 15, 2018, Dr. Marie Carlos borrowed P800,000

from Mrs. Josefina Ramos. Dr Carlos executed a promissory note,
herein attached as Annex ‘A’ that states:
"For value received, I promise to pay Mrs. Josefina Ramos

the sum of P800,000 on January 15, 2019 with 15% interest per
annum. Signed on January 15, 2018 in Quezon City." (Signatures of
Dr. Marie Carlos and borrower and Mrs. Josefina Ramos as lender
both appear on the PN).
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 B and C.
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 800,000
Php with an interest of 15% per annum.
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 50,000
Php.
WHEREFORE, plaintiff respectfully prays for judgment in

his favor through a Decision directing defendant to pay him
800,000 with an interest of 15% per annum as ACTUAL
DAMAGES and 50,000 Php as Attorney’s Fees.
Other just and equitable reliefs are also prayed for.
Quezon City; February 15, 2019
[SIGNATURE]
Michael Geoffrey A. Uy
Counsel for Plaintiff
24G The Eton Residences Greenbelt
Legazpi St., Legazpi Village, Makati City
IBP Lifetime No. 0101010/1-1-2019
PTR No. 4992321/12-21-2018/Mla.
Roll No. 29192
MCLE Exemption No. V 323132312/1-2-2019
Tel No. 1232892
VERIFICATION & CERTIFICATION AGAINST FORUM

SHOPPING
I, Josefina Ramos, of legal age, do hereby state that: I am the

plaintiff in the pleading/document entitled Complaint for Sum of
Money 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

February 15, 2019.
[SIGNATURE]
Josefina Ramos
SUBSCRIBED AND SWORN TO before me in the City of

Quezon City on this day of 02-15-2019, affiant exhibiting before me
his Government Issued ID no. 1 issued on 2-15-2015 at Quezon
City.
[SIGNATURE
]
Juan Juan
Notary Public
Until 2021
PTR No.12312312
Issued at Quezon City
On 01-01-2017
Doc. No. 2
Page No. 2
Book No. 2
Series of 2019
Annex A
Promissory Note
"For value received, I promise to pay Mrs. Josefina Ramos the sum of
P800,000 on January 15, 2019 with 15% interest per annum. Signed on
January 15, 2018 in Quezon City." (Signatures of Dr. Marie Carlos and
borrower and Mrs. Josefina Ramos as lender both appear on the PN).
Annex B
First Demand Letter
"Dear Dr. Marie Carlos,

I am writing to remind you that you promised to pay me back the
P800,000 you borrowed as shown by the attached promissory note that
we both signed on January 15, 2018. I am disappointed that until now,
you have not paid.
I am making this final demand for payment within 5 days from the time
you receive this letter. If you do not pay, I am sorry but I will have to
refer this to my lawyer for further action.
(signed)
Josefina Ramos".
Annex B
Second Demand Letter
Dear Dr. Marie Carlos,

I write on behalf of my client, Mrs. Josefina Ramos, in connection with
the amount of P800,000 which you borrowed from her on January 15,
2018. You agreed to pay her on January 15, 2019 with an interest of 15%
per annum. A copy of the promissory note signed by you is attached.
Despite her demand letter dated January 20, 2019 which you received
on January 21, 2019, you have not paid.
Kindly consider this as a final demand upon you to pay my client the
amount of P800,000 plus interest of 15% p.a. from due date until full
payment. You are given 5 days from receipt of this letter within which to
pay.
Otherwise, we shall be constrained to take legal action against you and
hold you liable not only for the principal amount and interest agreed
upon but also for all damages, attorney's fees and expenses that my
client shall incur.
We trust that you will give this your preferential attention.
(Signed)
Your name"

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Republic of the Philippines

Regional Trial Court

Marie Carlos and Diego Carlos,

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, and resident of 1598

2. On January 15, 2018, Dr. Marie Carlos borrowed P800,000

"For value received, I promise to pay Mrs. Josefina Ramos

4. Resort to the Barangay Conciliation process proved

5. Defendant’s obligation is due and demandable and

6. By reason of defendant’s unreasonable failure or refusal to

WHEREFORE, plaintiff respectfully prays for judgment in

Other just and equitable reliefs are also prayed for.

Quezon City; February 15, 2019

VERIFICATION & CERTIFICATION AGAINST FORUM

I, Josefina Ramos, of legal age, do hereby state that: I am the

IN WITNESS WHEREOF, I have signed this instrument on

SUBSCRIBED AND SWORN TO before me in the City of

"Dear Dr. Marie Carlos,

Dear Dr. Marie Carlos,

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