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REPUBLIC OF THE PHILIPPINES

(COURT)
(REGION)
(BRANCH)
(CITY)
Harry Potter
Plaintiff,
Civil Case No. 8910
-versus-
Lord Voldemort
Defendant.
X--------------------------------------------------------x
COMPLAINT
Plaintiff, by counsel respectfully states that:
1. He is a Filipino Citizen, of legal age, single and resides at Gryffindor St.,
Hogwarts Cebu City.

2. Defendant is a Filipino Citizen, of legal age, single and resides at Slytherin,


Dark Hollow Cebu City.

3. On January 11, 2014 he employed the services of the defendant as architect


and contractor for the construction of a house at Diagon Alley, Cebu City as
evidenced by the contract attached as Annex A.

4. As agreed, the defendant undertook to complete the construction of the


house on September 11, 2014 without any extension or grace, with a penalty
of P50,000 per week if the said construction is not accomplished on time.

5. As a first cause of action, on September 11, 2014 the construction of the


house was still incomplete as it remained unpainted, the doors and windows
were not installed and the plumbing and electrical system was not
completely set up.
6. As a second cause of action, from being unable to complete the construction
on time there were large cracks on the walls and broken tiles.

7. As a result, he demanded the defendant to accomplish the construction, and


repair the wall cracks and broken tiles.

8. The defendant refused claiming that he is no longer liable as the period of


the contract has expired.

9. Due to such refusal, the dispute was referred to the Lupong Tagapamayapa,
but the parties failed to arrive at a settlement.

10.On the account of the defendant’s refusal to complete the construction of the
house , plaintiff was compelled to initiate the suit and hire the services of
counsel for the amount of Php 120,000.00.

PRAYER
WHEREFORE, it is respectfully prayed that a judgment be rendered ordering the
defendant:
1. To complete the construction of the house within one month, and to repair
the damaged walls and floors;
2. To pay the penalty in the sum of Php 200,000.00 with legal interest.
3. To pay for actual damages worth Php 100,000.00
4. To pay the costs of the suit and attorney’s fees for the amount of Php
120,000.00
5. To pay for other just and equitable remedies under the premises.

Done this 7th day of January 2015 in Cebu City, Philippines.

ATTY. HERMOINE GRANGER


Counsel for Plaintiff
Notary Public
PTR No. 143, March 23, 2014
IBP Lifetime No. 123940, March 23, 2014
Roll No. 143
MCLE No. 8910
TIN No. 876-089-224
CTC No. 832847024, March 23, 2014.

REPUBLIC OF THE PHILIPPINES )


CITY OF XXX ) S.S.
VERIFICATION/CERTIFICATION
I, HARRY POTTER, Filipino citizen, of legal age, single and a resident of
Gryffindor St., Hogwarts Cebu City, Philippines after having been sworn in
accordance with law do hereby depose and say that:
1. I have caused the preparation of this complaint;
2. I have read all the contents and allegations thereof and acknowledge that the
same is true and correct of my knowledge and belief;
3. I hereby certify that I have not commenced any other action or proceedings
involving the same issue in any court, tribunal or quasi-judicial agency, that
to the best of my knowledge no action or proceeding is pending in any court,
tribunal or quasi-judicial agency; that if there are any such action or
proceeding which is either pending or terminated, I must state the status
thereof; and that if I should thereafter learn that a similar action has been filed
or pending before any court, tribunal or quasi-judicial agency , I undertake to
report the fact within five(5) days therefrom to the court or agency wherein
the original pleading and sworn certification completed herein have been
filed.
IN WITNESS WHEREOF, I have hereto affixed my signature on this 7th day
of January 2015 in the City of Cebu, Philippines.

(SGD.)HARRY POTTER
Affiant/ Plaintiff