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REPUBLIC OF THE PHKIPPINES 7TH JUDICIAL REGION REGIONAL TRIAL COURT CITY OF CEBU

Christine Manapsal Plaintiff -versusFil Ame G. Rabanes Defendant x---------------------------x CIVIL CASE NO._____________

COMPLAINT PLAINTIFF, by the undersigned counsel, to this Honorable Court respectfully alleges that: 1. Plaintiff is a Filipino, single , of legal age and a resident at 77 Brgy. San Antonio, Don Pedro Qui St. Cebu City, while defendant is of legal age married , Filipino and a resident at 1093 V.Rama Ave., Guadalupe Cebu City; 2. The defendant borrowed from plaintiff the amount of One Million Pesos (1,000,000.00) the former promised to pay the amount on January 16,2013 as one year after her acceptance of the same and secured the loan by a real estate mortgage over a parcel of land located at Gen . Echavez St. Cebu City, as evidenced by an agreement executed on the same date, a copy of which is hereto attached as Annex A hereof; 3. Defendant failed to pay the said loan on the due date thereof, and continues to fail to pay the same until the present, despite several oral and written demands . 4. Due to defendants unjustified failure to comply with plaintiffs just and valid claim, plaintiff was compelled to initiate this action and to retain the services of the undersigned counsel and to incur expenses in the amount of Seventy Five Thousand Pesos ( P75,000.00) as and by way of attorneys fees.

WHEREFORE, it is respectfully prayed that, after due hearing, Judgement be rendered ordering the defendant to pay the plaintiff the amount of 1,000,000.00 plus attorneys fees. Plaintiff prays for such other and further reliefs as may be just or equitable under the premises. Cebu City , March 15, 2013.

Lucille M. Teves Counsel for the Plaintiff Rm. 335JPIC Building Pelaez St. Cebu City

PTR. O.R .No.876 Cebu City ,Jan.3,2013 IBP O.R.No. 654321 Cebu City, Jan.3,2013 Attorneys Roll No. 4123, May 2001

CERTIFICATION AGAINST FORUM SHOPPING I, Christine Manapsal , do hereby certify that I am the plaintiff in the above titled case, that I have caused the preparation of the foregoing civil case, that the plaintiff has not filed any other case in any other court or tribunal involving the same cause of action that I am not aware of any pending case involving the same cause; and that should I hereafter acquire knowledge of such action, I will notify this Honorable Court thereof within five (5) days from acquiring such knowledge. Cebu City, March 15,2013 In WITNESS WHEREFORE , I have hereunto set my hand in the date and place stated above.

Christine Manapsal

SUBSCRIBED &SWORN to before me this 15th day of March,2013, the affiant exhibiting to me her Passport Number AV 3426 issued at Cebu City on September 23,2005.

Gil Rodriguez NOTARY PUBLIC Until December 31,2013

Doc. No. 4; Page No. 5; Book No. 2; Series 2013

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