REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BACOLOD CITY, BRANCH IX
NENA ROSE Z. BUGRONG
Plaintif
versus
NO. 12345566

CIVIL CASE
FOR: Collection of a Sum of
Money

ROSHAN LANES TAGALIBOD

Defendant
xx
COMPLAINT
PLAINTIFF, thru the undersigned counsel, unto this
Honorable Court respectfully alleges:
1. The Plantif is of legal age, Filipino, single and with
residence at #11 Kabukiran Street, Brgy. San Birhen, Bacolod
City;
2. That the defendant ROSHAN LANES TAGALIBOD is
likewise of legal age, Filipino, single and with a residence at
Blk 5, lot 5, Bangga Cegasco, Purok Pahanocoy, Brgy. Sumag, Bacolod City, where she could be served with summons
and other processes of the court;
3. That on June 21, 2013, the defendant obtained a loan
from the plaintif in the sum of Fifty Thousand Pesos and Fifty
Centavos (P50,000.50) to be fully paid on its due date which
is on June 21, 2014 as evidenced by a promissory note dated
June 21, 2013, a photocopy of which is hereto attached as
Annex A;
4. That defendant was able to pay only the amount of
P1,000.50 from the principal amount despite the lapse of the
period to pay the loan, defendant failed to pay her the total
obligation thereby entitling the plaintif to be paid of the
1

unpaid principal in addition to the agreed 30% per annuity

by way of interest and 30% per annum by way of penalty,
photocopy of statement of account is hereto attached as
Annex B and made an integral part hereof;
5. That said loan now long overdue despite of repeated
demands and she failed and refused to pay the same as
evidenced by the Demand Letters send by the Plaintif,
photocopy of which is hereto attached as Annex C and
made an integral part hereof;
6. The repeated demands were made for the defendant
to pay her obligations but she failed to pay.
WHEREFORE, Plaintif respectfully prays for judgment in
its favor through a decision directing the defendant:
a. To pay Plaintif the sum of Forty Seven Thousand Five
Hundred Pesos (P49,000.00 with interest at 30% and 30% as
penalty from June 21, 2014 until the full amount is paid;
b. Attorneys Fees at 10% of the principal amount;
c. the cost of the suit
Other just and equitable reliefs are also prayed for.
Bacolod City, Negros Occidental, February 25, 2015

ATTY. CARLO FRANCES E. CABALLERO

Counsel for the plaintif
NOBC Bldg., Gatuslao St., Bacolod City
Attorneys Roll No. 098532
IBP No. 24525-01/03/15-Bacolod
PTR No. 53532- 01/03/15-Bacolod
MCLE Compliance No. IV-0012345 November 17, 2014

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
I, NENA ROSE Z. BUGRONG, of legal age, after having been
duly sworn in accordance with law, depose and state that:
1. I am a plaintif in the foregoing Complaint for Sum of
Money;
2. I caused the preparation of the Complaint, which I have
fully read and understand;
3. I have read the contents thereof and the facts stated
therein are true and correct of my personal knowledge
and/or on the basis of copies of documents and records in
my possession;
4. I have not commenced any other action or proceeding
involving the same issues in the Supreme Court, the Court
of Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or
proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or
proceeding has been filed or is pending before the
Supreme Court, the Court of Appeals, or any other tribunal
or agency, I undertake to report that fact within five (5)
days therefrom to this Honorable Court.

NENA ROSE Z.BUGRONG

Affiant
SUBSCRIBED AND SWORN to before me this
25 day of February 2015 at Bacolod City, affiant exhibiting
to me his Community Tax Certificate No. 12345677 issued on
January
3,
2015
at
Bacolod
City.
th

ATTY. CARLO FRANCES E. CABALLERO

NOBC Bldg., Gatuslao St., Bacolod City
Attorneys Roll No. 098532
3

IBP No. 24525-01/03/15-Bacolod

PTR No. 53532- 01/03/15-Bacolod
MCLE Compliance No. IV-0012345 November 17, 2014
Doc. No. 22
Page No. 32
Book No. 01
Series of 2015