Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, and resident of 6750 Forbes Park, Makati City; defendant is also a Filipino, of legal age and resident of 6752, Forbes Park, Makati City, where he may be served with summons and other processes.

2. Sometime in January 2005 and over a period of six (6) months, defendant borrowed certain amounts from plaintiff. Defendant promised to pay these amounts on an installment basis monthly. These amounts now total Nine Hundred Thousand Pesos (P900,000.00).

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 A and B.

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 Nine Hundred Thousand Pesos (P900,000.00) plus legal interest.

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 Fifty Thousand Pesos (P50,000.00).

WHEREFORE, plaintiff respectfully prays for judgment in his favor through a Decision directing defendant to pay him NINE HUNDRED THOUSAND PESOS (P900,000.00), with legal interest, as ACTUAL DAMAGES and FIFTY THOUSAND PESOS (P50,000.00) as Attorney’s Fees.

Other just and equitable reliefs are also prayed for.

Quezon City for Makati; 13 April 2007.

(Sgd.) _____________________________

Counsel for Plaintiff