Professional Documents
Culture Documents
Defendants
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C O M P L A I N T
PLAINTIFF through the undersigned counsel and unto this Honorable
Court most respectfully alleges that:
1. RODOLFO GUAZON, Plaintiff is of legal age, married,
Filipino citizen and a resident of Barangay Caunayan, Batac,
Ilocos Norte;
2. AMELIA GUAZON is also of legal age, married, Filipino citizen
and a resident of Barangay Caunayan,Batac, Ilocos Norte. She is the
legal wife and the Attorney-
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Complaint
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even left words of assurance that she will return all the goodness
done to her when time comes that she will also be of help to
Plaintiff’s family;
8. Sometime 2013, Plaintiff received a text message from Defendant
Dr. JESIE SALONGA asking for financial help. She was reviewing
then in Manila for her medical board exams. Again, due to his
desire to help Defendant Dr., he extended financial help by lending
money by depositing it to the account of the Defendant doctor and
money remittances every time she would ask for money. Copies of
these bank deposit slips and money remittances are hereto attached
and marked as Annexes “B” and series;
9. The Plaintiff would also send money through Mrs. Leslie Baluyot,
wife of his co-worker abroad, who live in Binangonan, Rizal, to
whom Defendant doctor would usually picked and get said money;
10. A total of Three Hundred Fourteen Thousand Pesos (Php
314,000.00) has been borrowed by the Defendant doctor with the
agreement with the Plaintiff that she will pay the same when she
will be able to look for a job after taking her board exams. She also
promised that she will going to return the favor she has been
receiving from the Plaintiff by helping his children when time
comes that they will also be needing help specially in their
schooling.
These promises were all held by the Plaintiff. He kept in his mind
the fact that he wanted to help and that he also wanted to have the
Defendants to have a good future for the reason that, at that time,
their mother just past away due to sickness and he knows fully well
that they are in financially incapable to support the education of
Defendant doctor;
11. True enough Defendant Dr. was able to pass the medical board
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Complaint
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22. That due to the unlawful refusal to pay of the Defendants ,
Plaintiff incurred and suffered actual damages the amount of which
shall be proved during the proceedings of the instant case;
23. That Plaintiff also suffered sleepless nights, wounded feelings,
anxiety and fright the amount of which is left to the sound discretion
of the court;
24. That as further consequence of the Defendants unlawful and unjust
refusal to pay, the Plaintiff was constrained to seek he services of a
counsel to litigate his case and to protect his rights of which Defendants
must pay to Plaintiff in the concept of legal expenses and Attorney’s fees
the amount of which is left to the discretion of the court.
PRAYER
WHEREFORE, WITH ALL THE FOREGOING, it is respectfully prayed this
Honorable Court that judgment be rendered in favor of herein Plaintiff and
against the Defendants and to:
1. Order Defendant Mrs. JOSEFINA SALONGA (deceased) represented
by Mr. HENRY SALONGA ( surviving spouse) to pay the amount of
One Hundred Six Thousand Pesos (Php 106,000.00) plus legal
interest thereon counted or reckoned with from the filing of this
Complaint until the total amount is paid;
2. Order Defendant Dr. SALONGA to pay the amount of One Hundred
Three Hundred Fourteen Thousand Pesos (Php 314,000.00) plus
legal interest thereon counted or reckoned with from the filing of
this Complaint until the total amount is paid;
3. Order the Defendants to pay Plaintiff actual, moral and attorney’s
fees the amount of which is left to the sound discretion of this
Honorable Court;
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Complaint
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Sudayon, Rhina
Counsel for Plaintiff