REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

REGIONAL TRIAL COURT
City of Malolos, Bulacan

ATHENA S. DIMAAPI,
Plaintiff,
-versus-

CIVIL CASE No. __________

For: Action for Sum of Money

AMIDALA I. CRUZ,
Defendant.
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COMPLAINT
COMES NOW the plaintiff, through the undersigned counsel,
and unto this Honorable Court, most respectfully states:
1. That the plaintiff is of legal age, a Filipino Citizen and
residing at 143 Sitio Rosal, Sta. Barbara, Baliuag, Bulacan;
2. That the defendant likewise is of legal age, a Filipino citizen
123 Maligaya St., Sto. Cristo, Pulilan, Bulacan, where she
may be served with summons and other processes of this
Court;
3. That on 10 July 2014 , the defendant obtained a loan from
the plaintiff the sum of Three Hundred Fifty-Four Thousand
Pesos (Php354, 000.00), Philippine Currency, with the
following terms and conditions:
a. The principal obligation shall be payable in six (6)
months from the time of the execution of the
agreement;
b. The principal loan shall incur an interest of six per
centum (6%) for every month compounded; and
c. The loan was to mature on 10 January 2015.

ACTION FOR SUM OF MONEY

Dimaapi v. Cruz
Page 2 of 4

4. That the said loan, now overdue and despite repeated

demands made orally and in writing by the plaintiff, defendant
refused and failed to pay the amount as evidenced by the
demand letter sent by the counsel for the plaintiff dated 4 July
2015, a photocopy of which is hereby attached as Annex A
and made an integral part hereof.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed that this Honorable Court:
1. ORDER the defendant to pay the sum of Three Hundred
Fifty Thousand Pesos (Php350,000.00), with interest thereon
at the rate of six per centum (6%) for every month
compounded from 10 July 2014, und until the same is fully
paid;
2. ORDER the defendant to pay the costs of the suit.
Other reliefs, just and equitable are hereby likewise prayed for.
Manila, 16 July 2015.
ALCANTARA CHUA QUIRINO
ULARDE ICO TAN LAW OFFICES
Counsel for the Plaintiff
1/F ACQUIT LAW Bldg.,
*insert address here*

For the Firm:

AIRIZ M. DELA CRUZ

Roll No.
IBP No. 756555
PTR No.
MCLE Compliance No.

ACTION FOR SUM OF MONEY

Dimaapi v. Cruz
Page 3 of 4

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING
I, ATENA S. DIMAAPI, Filipino, of legal age, and residing at
143 Sitio Rosal, Sta. Barbara, Baliuag, Bulacan, after having been
sworn in accordance with law, hereby states that:
1. I am the plaintiff in this instant case;
2. I have read the contents of the foregoing complaint and the
allegations therein are true and correct based on my own
knowledge and/or based on the records on hand;
3. I have not commenced any other action involving the same
issues before any court, tribunal or quasi-judicial agency
and, to the best of my knowledge, no such other action or
claim is pending therein;
4. No such actions or proceedings is pending before any court,
tribunal or quasi-judicial agency; and,
5. Should I learn that the same or similar action or claim has
been filed or is pending before any court, tribunal or quasijudicial agency, I undertake to promptly inform this Court
within five (5) days therefrom.

ATENA S. DIMAAPI
Affiant
SUBSRCIBED AND SWORN to before me this 16th day of July
2015, affiant exhibiting to me his Voters ID No. issued in Pulilan,
Bulacan on 28 May 2010.

AIRIZ M. DELA CRZ

Notary Public
Commission No.
Until 31 December 2015
Roll No.
IBP No.

ACTION FOR SUM OF MONEY

Dimaapi v. Cruz
Page 4 of 4

PTR No.
MCLE Compliance No.
Doc. No.
Page No.
Book No.
Series of

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