REPUBLIC OF THE PHILIPPINES

6TH JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
BRANCH 6
ILOILO CITY
JOSEFINA G. DEGRACIA,
Plaintiff,
Civil Case No.0002-2015
For: Collection of Sum
of Money

- versus AMBROSIO T. TOREJOS,

Defendant,
x-----------------x
COMPLAINT

Plaintiff, by counsel and to this Honorable Court, respectfully states

that:
The Parties
1. Plaintiff is Filipino, of legal age, married and a resident of No. 20,
Sto. Domingo St. Jaro, Iloilo City, Philippines. For purposes of this
action, plaintiff may be served with all orders, notices, and other
processes of this Honorable Court through the office address of the
undersigned counsel indicated below;
2. Defendant also a Filipino, of legal age and may be served with
summons and other processes of this Honorable Court at his last
known address at No.21 Woodbridge Subdivision, Jaro, Iloilo City,
Philippines;
The Facts
3. That on August 1, 2014, defendant executed a promissory note in favor
of the plaintiff in the amount of P150, 000.00 payable within 30 days
from the date of the promissory note. A true and faithful machine
reproduction of the Promissory Note made by the Defendant is hereto
attached as Annex "A";
4. That the 30-day period had elapsed and Despite Plaintiff's repeated
demands, both written and verbal, Defendant failed, neglected and
refused, and continues to fail and refuse to pay the amount stated in
the promissory note. A true and faithful machine reproduction of the
Plaintiff's demand letter to Defendant dated September 30, 2014 is
hereto attached as Annex "B";

5. That due to the unjust refusal of defendant to comply with the

demands, plaintiff was compelled to file the instant action engaging
the services of counsel in the amount of P10,000.00.

PRAYER

WHEREFORE, after due notice and hearing, Plaintiff respectfully

prays that judgment be rendered against the Defendant as follows:
1. Ordering the Defendant to pay Plaintiff the sums of:
a. The amount of P 200,000.00, with legal interest as actual
damages and P10,000.00 as Attorney's Fees plus
Appearance Fee;
2. Plaintiff respectfully prays for such other reliefs as may be just and
equitable in the premises.
Iloilo City, Philippines, January 3, 2015.

ATTY. JOSHUA C. BAJADA

Counsel for the Plaintiff
19 Sto. Domingo St., Jaro Iloilo City
IBP NO. 001122, 1/02/15, Iloilo City
PTR NO. 000123-12, 1/02/15, Calinog, Iloilo
ROLL ATTORNEY NO. 23556
MCLE Comp. No. IV-0089009, 3/2/12

VERIFICATION AND CERTIFICATION

I, Josefina G. Deggracia, of legal age, after having been duly sworn
in accordance with law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
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.

Josefina G. Degracia
Affiant
SUBSCRIBED AND SWORN to before me, this 13th day of
October, 2014 in Iloilo City, Philippines, affiant exhibiting to me Tax
Identification No. 221-005-890 issued on January 7, 2010.

ATTY. JOSHUA CIMENI BAJADA

Notary Public
For the City and Province of Iloilo
Notarial registry No.: 0098
Valid Until December 31, 2015
IBP NO. 001122, 1/02/15, Iloilo City
PTR NO. 000123-12, 1/02/15, Calinog, Iloilo
ROLL ATTORNEY NO. 23556
MCLE Comp. No. IV-0089009, 3/2/12

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