Republic of the Philippines

Regional Trial Court

7th Judicial Branch
Branch No.____
Cebu City

MILO,
Plaintiff
Civil Case No. _____
-versus- For: Sum of Money

JIFEL,
Defendant
x-----------------------------------------------x

COMPLAINT

COMES NOW, the undersigned counsel, and unto this Honorable Court,
respectfully manifest:

1. Plaintiff, MILO is a Filipino, of legal age and resident of 124, Fortuna

Street, Pooc, Talisay City; Defendant, JIFEL, is also a Filipino, of
legal age, and resident of 218123, Fortuna Street, Pooc, Talisay City,
where he may be served with summons and other processes.

2. Sometime in February 14, 2000 and over a period of one (1) year,
Defendant borrowed money from Plaintiff sum of money in total
amount of FIVE HUNDRED THOUSAND PESOS (P 500,000.00).

3. Due to their friendship, MILO agreed to grant JIFEL a loan and gave
him FIVE HUNDRED THOUSAND PESOS (P 500,000.00).

4. Plaintiff asked the Defendant to execute a Promissory Note in lieu of

the loan; refer to ANNEX A;

5. Upon maturity, oral demand was made by the Plaintiff to Defendant

for the payment of his indebtedness but Defendant failed to pay the
Plaintiff and instead asked to be given a one-year extension to which
the Plaintiff refused;

6. Plaintiff then wrote and sent the Defendant a demand letter for the
payment of the loan of FIVE HUNDRED THOUSAND PESOS (P
500,000.00) plus legal interest after the debt became due and
demandable within 10 days upon receipt; refer to ANNEX B;
 7. In spite of the previous repeated oral and written demands made by
Plaintiff, Defendant merely ignored the same and obstinately refused
to settle his indebtedness.

8. By reason of Defendant’s failure or refusal to pay his due and

demandable obligation, Plaintiff was obliged to hire the services of a
lawyer who is entitled to attorney’s fees of TWENTY-FIVE
THOUSAND PESOS (P 25,000.00).

WHEREFORE, the above premises considered, it is respectfully prayed of

this Honorable Court after hearing on the merits, that;

a. Defendant be ordered to pay his indebtedness of FIVE

HUNDRED THOUSAND PESOS (Php 500,000.00) which has
become due and demandable on February 14, 2001.

b. Defendant also be ordered to pay legal interest of TWELVE

PERCENT (12%) per annum from the maturity date until the
date of full payment there of.

c. Defendant be ordered to pay the costs of this litigation.

Other relief just and equitable under the law are likewise prayed for.

Cebu City, Philippines, this 23rd day of February, 2017.

ATTY. MICAH JONA A. PAN, CPA

Counsel for Petitioner
Pan & Associates Accounting and Law Office
th
7 F, Keppel Bldg, Cebu Business Park, Cebu City
Roll of Attorneys No. 0712992
IBP No. 0712992 Lifetime/Cebu City
MCLE No. 3233882
PTR No. 12345678
 VERIFICATION AND CERTIFICATION AGAINTS FORUM
SHOPPING

I, MILO, Filipino, of legal age, married and resident of 124 Fortuna

Street, Pooc, Talisay City, Cebu, after having been sworn to in accordance
with law depose and say that;
I am the Plaintiff in the above-titled case and have caused the
preparation of this Complaint;

I have read the same and knows the contents thereof and the
allegations contained therein are true and correct of my own personal
knowledge.

To the best of my knowledge and belief, no such action or proceeding

is pending before any court or any other tribunal or agency;
If I should I learn of such a case, I shall notify this Honorable Court
within five (5) days from my notice.

IN WITNESS WHEREOF, I have hereunto set my hand this 27th day

of February 2018 of Cebu City Philippines.

MILO
Affiant

SUBSCRIBED AND SWORN to before me this 27th day of February

2018, by MILO, who exhibited to me his Driver’s License No. 1234567
issued at Cebu City, Philippines on July 2017.

Doc. No.: 1
Page No.: 1
Book No.: 1
Series of 2018.

ATTY. MICAH JONA A. PAN, CPA

Counsel for Petitioner
Pan & Associates Accounting and Law Office
th
7 F, Keppel Bldg, Cebu Business Park, Cebu City
Roll of Attorneys No. 0712992
 IBP No. 0712992 Lifetime/Cebu City
MCLE No. 3233882
PTR No. 12345678

ANNEX A
PROMISSORY NOTE

I, JIFEL, promise to pay MILO the sum of FIVE HUNDRED

THOUSAND PESOS ONLY (Php 500,000.00) with one-year maturity
period. Full Payment be made upon maturity, February 14, 2001.
In case of default, legal interest of TWELVE PERCENT (12%) per
annum shall automatically apply starting February 15, 2001 until fully paid.
IN WITNESS THEREOF, I set my hand under seal this 14 th day of
February, 2000 and I acknowledge receipt of a completed copy of this
instrument.

JIFEL
Sign Notary Public

Name and Address

 ANNEX B
DEMAND LETTER

February 25, 2001

JIFEL
123 Fortuna Street,
Pooc, Talisay City, 6000

Dear Mr. JIFEL,

This letter is pursuant to your promise to pay your indebtedness of
FIVE HUNDRED THOUSAND PESOS (Php 500,000.00) on February 14,
2000 which has become due and demandable this February 14, 2001 or a
year after you contracted the loan.
Please settle such within TEN (10) days upon receipt of this letter.

Respectfully,

MILO ENERGY DRINK