Complaint For Sum of Money

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REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT OF BATANGAS  JUDICIAL DISTRICT BRANCH ___  JUAN DELA CRUZ,
Plaintiff,
Civil Case No. __________________ -
 
versus - For: Sum of Money
PEDRO SANTOS,
Defendant,
x ------------------------------------- x
COMPLAINT
PLAINTIFF,
through counsel, most respectfully states: 1.
 
That plaintiff is a Filipinio, of legal age, marreid and residing at C. Tirona St., Batangas City, whereas defendant is likewise a Filipino, of legal age, single and residing at 123, Alalum, San Pascual, Batangas, at which addresses the parties herein may be served with summons and other court processes; 2.
 
That plaintiff is a sole proprietor engaged in the sale of poultry feeds and supplies, doing business under the name Juan Poultry Supply, with business address at C. Tirona St., Batangas City. It sells poultry feeds and supplies on cash and on credit subject to a 5% interest to certain trusted clients. Purchases on account shall be payable within ten days from the date of the invoice. 3.
 
That on October 13, 2022, plaintiff reviewed the records of defendant, and it appeared that he made the following purchases on account:
Date Sales Invoice No. Amount
Oct. 2, 2021 12301 Php200,000.00 Nov. 6, 2021 12311 Php100,000.00 Dec. 5, 2021 12315 Php300,000.00  Jan. 5, 2022 12325 Php150,000.00 Feb. 9, 2022 12335 Php250,000.00
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Mar. 3, 2022 12350 Php180,000.00
Total (exclusive of interest) Php1,180,000.00
4.
 
That the records also revealed that defendant made no payment on the above purchases. 5.
 
On 13 October 2022, a demand letter was personally served and several personal demands were made by the credit collector of herein plaintiff but defendant failed to pay. It has been more than ten days since the receipt but defendant shows no intention of paying. 6.
 
That the defendant has failed and refused and still fails and refuses to pay the said indebtedness on due date, with the corresponding interest thereon to the herein plaintiff, despite repeated demands.
 WHEREFORE,
it is most respectfully prayed for of this Honorable Court that after due hearing, judgement be rendered in favor of plaintiff and against the defendant in this manner: a.
 
Ordering the defendant to pay plaintiff the amount of One Million, One Hundred Eighty Thousand Pesos (Php1,180,000.00), plus interest thereon at the rate of 12% per annum from October 2019, and until the same is fully paid; and b.
 
Ordering the defendant to pay the costs of this suit. Plaintiff likewise prays for such other and further relief or reliefs as this Honorable Court may deem just and equitable in the premises. Batangas City, 18 November 2022
BENJAMIN LUKE PHILLIP G. VERDADERO
Roll of Attorneys No. 12345 IBP No. 123456 PTR No. 1234567 / January 03, 2023 MCLE Compliance No. VII-1234567 / April 06, 2023 Email address: lukeverdadero@gmail.com
 
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