REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Cebu City, Cebu
Branch 12
RONALD Y. ILIS,
Plaintiff,
CIVIL CASE NO. 45677
FOR: COLLECTION OF SUM
OF MONEY, DAMAGES, and
ATTORNEYS FEE
-versusARNOLD F. SUBANG,
Defendant,
x--------------------------------------/

COMPLAINT
Plaintiff, by counsel and to the Honorable Court respectfully alleges that:
1. Plaintiff is of legal age, Filipino, married and a resident Of Barangay
Lawaan II, Talisay City, Cebu, whereas defendant is of legal age,
Filipino, married and a resident of Barangay Tisa,Cebu City, Cebu
where they may be served with summons and other processes of
the Court;
2. Plaintiff and defendants are bestfriends since childhood;
3. On February 14, 2000, defendant approached plaintiff and pleaded
to borrow money from the plaintiff the amount of FIVE HUNDRED
THOUSAND (P500, 000.00) PESOS which he promises to pay
within a period of one(1) year;
4. Due to their friendship, plaintiff agreed to lend money to the
defendant in the amount of P500, 000.00.
5. Upon the advice of a lawyer friend, the plaintiff asked defendant to
execute and sign a promissory note specifying the amount loaned

and the one-year maturity date, a copy of the said note is hereby
attached and marked as Annex A hereof;

6. When maturity date came, the plaintiff verbally asked the defendant
to pay his indebtedness, as he is in dire need of money as his silver
wedding anniversary to his wife is fast approaching.
7. Unfortunately, the defendant refused to pay the plaintiff and insisted
that he be given a period of one (1) year to settle his indebtedness,
as his silver anniversary to his wife is also fast approaching.
8. In view of the defendants refusal to settle his obligation, plaintiff
was left with no other recourse but to send him a demand letter
requesting him to settle his indebtedness in the amount of FIVE
HUNDRED THOUSAND (P500, 000.00) PESOS within ten
(10)days from receipt thereof, copy of the Demand Letter is herein
attached and marked as Annex B hereof;
9. Despite of previous repeated oral and written demands made by
the plaintiff, the defendant merely ignored the same and obstinately
refused to settle his indebtedness.
10. Feeling that the chance to recover said amount extra-judicially was
nil, herein plaintiff was constrained to hire the services of the
undersigned counsel to protect her interest and help her enforce
her rights against the defendant;
11. Plaintiff repleads and reiterates all preceding allegations in this
complaint and further alleges that:
a.) In order to vindicate the rights of the plaintiff violated by
defendant, the plaintiff is now constrained to institute present
action thereby retaining counsel to whom she has bound
herself to pay the sum of P35, 000.00 by way of attorneys
fees and P1, 500.00 per court appearance;
WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed of
the Honorable Court to render judgment:

1. Ordering defendant to pay plaintiff the sum of FIVE HUNDRED

THOUSAND (P500, 000.00) PESOS representing her unpaid

indebtedness in favor of the plaintiff and its reasonable interest at
the sound discretion of the Honorable Court;
2. Ordering defendants to pay plaintiff the sum of P35, 000.00 by way

of attorneys fees.
3. Ordering defendant to pay plaintiff the sum of P40,000.00 by way of
exemplary damages in order to deter any person from emulating the
iniquitous act exhibited by herein defendant, moral damages in the
amount of P60,000 for the serious anxiety, sleepless nights, wounded
feelings and besmirched reputation;

Plaintiff prays for such other relief or remedy consistent with law and
equity.
Cebu City, Philippines, February 25, 2015.

MA.GABRIELLEN C. QUIJADA
Counsel for the Plaintiff
Roll No. 99977
QUIJADA & CASTOR LAW OFFICES
Nasipit, Talamban, Cebu City
IBP No. 111122, 02-01-2010, Cebu City
PTR No. 2222245, 02-01-2010
MCLE V No. 12345566, 02-01-2010, Pasig City

VERIFICATION/CERTIFICATION
I, RONALD Y. ILIS, plaintiff, after being sworn in accordance with law,
deposes and says: That I am the plaintiff in the above-entitled case; that I caused
the above complaint to be prepared and has read and knows the contents
thereof; that the allegations therein are true in my own knowledge.
I have not heretofore commenced any other action or proceeding involving
the same issues in the Supreme Court, the Court of Appeals, or any other
tribunal agency of hearing officer; to the best of my knowledge no such action or
proceeding is pending in the Supreme Court, the Court of Appeals, or any other
tribunal, agency or hearing officer; 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, agency or hearing officer, I undertake to report
that fact within five(5) days therefrom to this Honorable Court.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my
signature this 25th of February 2015 at Lapu-Lapu City, Philippines.

RONALD Y. ILIS
Affiant
CTC No. 09990099
Issued on January 5, 2015
Issued at Cebu City

SUBSCRIBED AND SWORN TO BEFORE ME this 25 February 2015 at

Cebu City, Philippines affiant exhibiting to me her Community Tax Certificate No.
issued on the date and place above-written.

Annex A
PROMISSORY NOTE

Promissory Note

February 14, 2000

RONALD Y. ILIS, the sum of FIFTY

THOUSAND PESOS (Php50,000.00) within one year after the date of this note.
FOR VALUE RECEIVED, I promise to pay

Sgd.

ARNOLD F. SUBANG

Annex B
DEMAND LETTER
ARNOLD F. SUBANG
Barangay Tisa, Cebu City,
Cebu
February 28, 2001
Dear Arnold:
In February 14 of 2000 you promised to pay your debt to me worth Five Hundred
Thousand pesos (P500,000) within one year. Your debt already matured and I
have made repeated attempts to collect, but you have not come forward with the
money. I am requesting that you settle your indebtedness within ten (10)days
from receipt thereof.
I will expect a response to this letter no later than March 10, 2010. If this matter is
not resolved by the time specified above, I reserve the right to commence legal
proceedings to recover the debt without further notice to you and this letter may
be tendered in court as evidence of your failure to pay.
Sincerely,
RONALD Y. ILIS