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REPUBLIC OF THE PHILIPPINES

SUPREME COURT
7th JUDICIAL REGION
MUNICIPAL TRIAL COURT IN CITIES
Branch _____, Cebu City

JUAN ILOK Civil Case No. _____________


Plaintiff
For: Sum of Money

-versus-

BRAD ARMPIT
Defendant
x---------------------------------x

COMPLAINT

COMES NOW, Plaintiff through the undersigned counsel respectfully avers that:

1. Plaintiff is of legal age, married and a resident of Barangay Pardo, Cebu City, Philippines. Plaintiff has
the capacity to sue and be subject for court process by which the court has jurisdiction over the
personality of the herein plaintiff;

2. Likewise, the defendant is of legal age, married and a resident of legal age, married and a resident of
Barangay Pardo, Cebu City, Philippines. Defendant has the capacity to be sue and be subject for court
process by which the court has jurisdiction over the personality of the herein defendant after the
summons will be duly serve;

3. On March 1, 2007, Defendant is indebted to the plaintiff in the amount of ONE HUNDRED FIFTY
THOUSAND PESOS (P 150,000.00) without any written contract and was witnessed by Pedro Siponon
and Jose Kogmohon;

4. Subsequently, On July 20, 2007, defendant went to the house of the plaintiff to cause partial payment
in the amount of FIFTY THOUSAND PESOS (Php 50,000.00);

5. Consequently, the aforesaid payment was received by the plaintiffs minor son aged 17 years old;
6. On July 31, 2007, defendant made its final payment in the amount of ONE HUNDRED THOUSAND
PESOS (P100,000.00) but the previous payment was not received by the plaintiff in lieu that his son was
not turn over the said money;

7. However, the plaintiff told the defendant that it was not his responsibility to rectify the payment by
mistake made by the defendant since the latter is still liable;

8. In lieu of the balance due thereon, plaintiff cause to file an action before the barangay against the
defendant;

9. Consequently, parties have never reached an agreement and cause the plaintiff to ask for the
issuance of certificate to file action (CTA);

Machine copy of the abovestated document is hereto attached as Annex A and made integral part of
this complaint;

10. In lieu of non-compliance hereof, the plaintiffs counsel send a demand letter to the defendant but
the latter did not head over the demand;

Machine copy of the abovestated document is hereto attached as Annex B and made integral part of
this complaint;

11. As provided by law, the plaintiff causes to file for collection suit against the defendant.

PRAYER

WHEREFORE, it is hereby respectfully prays that the court shall:

1. Ordering the defendant to pay the amount of FIFTY THOUSAND PESOS (P 50,000.00)

2. Ordering the defendant to pay 25% attorneys fees

Other just and equitable reliefs are likewise prayed for.

October 3, 2016 Cebu City, Philippines

ATTY. PARK K. TILAOPAO


Counsel for the Plaintiff
Unit 1234 Apple One Building
Cebu City, Philippines
Roll No. 123453, IBP Member Lifetime 3/12/12
PTR No. 23124, Cebu City 12/31/15
MCLE Compliance No. VI-23455, Series of 2015
Republic of the Philippines }s.s.
City of Cebu )s.s.
x------------------------------------x

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, Juan Ilok, 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.

Juan Ilok
Affiant

SUBSCRIBED AND SWORN to before me this __3_ day of October 2016 at Cebu City affiant
exhibiting to me his Competent Identification with number 12345-JEI-02934 (Voters ID) issued on
December 2 2001 at Maasin City.

Doc. No. 2 ; ATTY. Ramond E. Raloko


Page No. 3; Notarial Commision No. 132531
Book No. V; Issued on 2/12/14
Series of 2016. Roll No. 123453, IBP Member Lifetime 3/12/12
PTR No. 23124, Cebu City 12/31/15
MCLE Compliance No. VI-23455, Series of 2015

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