REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11th JUDICIAL REGION
BRANCH XVI

JAN BUSTAMANTE,
Plaintiff,

- versus - Civil Case No. 124356

For: Collection of Sum
Of Money with Prayer for
Preliminary Attachment
JUN PAL LOY,
Defendant.
x---------------------------------------x

COMPLAINT

PLAINTIFF, thru counsel, and unto this Honorable Court,

respectfully avers that:

1. Plaintiff, JAN BUSTAMANTE is a Filipino Citizen, of legal age,

single and a resident of 122 Marang St., NHA , Davao City, whereas,
defendant JUN PAL LOY is likewise a Filipino, of legal age, single,
and residing at 234 Sampaguita St., Lanang, Davao City, at which
address the party herein may be served with summons and other court
processes;
2. On December 21, 2018, defendant borrowed money to the plaintiff the
amount of ONE MILLION PESOS (P 1,000,000.00), which
indebtedness is due and payable on or before December 21, 2019,
with a interest at the 6% per annum within one (1) year, in accordance
with the promissory note executed by the defendant on the said date.
3. The defendant has failed and refused and still fails and refuses to pay
the said indebtedness on due date, with corresponding interest thereon
to the herein plaintiff, despite repeated request and demands.
4. The amount due the plaintiff is as much as the sum for which an order
of attachment is sought to be granted, above all legal counterclaims on
the part of the defendant;
5. Plaintiff is willing to put up a bond for the issuance of a preliminary
attachment in an amount to be fixed by the court, not exceeding the
sum of THREE MILLION PESOS equal to the amount of the
plaintiff’s claim, upon the condition that the plaintiff will pay the
costs that may be adjudged to the defendant and all damages which he
 may sustain by reason of the attachment, if this Court so adjudge that
the applicant was not entitled thereto.
WHEREFORE, it is respectfully prayed that:
1. Pending the hearing of this case, a writ of preliminary
attachment be issued against the property of the defendant to
serve as security for the satisfaction of any judgment that
may be recovered herein; and
2. After due hearing on the principal cause of this action,
judgment be rendered against the defendant for the sum of
THREE MILLION PESOS with interest at the stipulated
rate of 6% from December 21, 2019, plus cost of this suit.

Other reliefs just and equitable are likewise prayed for.

Davao City, February 12, 2020.

ADRIAN PAJARO
Counsel for Plaintiff
Until December 31, 2021
Attorney’s Roll No. 10772
PTR No. 7862245 B; 01-02-20; Davao City
IBP O.R. No. 024454; 01-02-20; Davao
City

REPUBLIC OF THE PHILIPPINES)

PROVINCE OF DAVAO DEL SUR) S.S
IN THE CITY OF DAVAO………..)
X…………………………………….X

VERIFICATION AND CERTIFICATION

I, JAN BUSTAMANTE, of legal age, after having been duly sworn in

accordance with law, depose and state that:
1. I am a petitioner in the above-stated case representing the republic
of the Philippines;
 2. I caused the preparation of the foregoing petition;
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 true and
authentic records.
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.

IN WITNESS WHEREOF, I have hereunto affixed my signatures this 2 nd

day of February 2019, at Davao City, Philippines.

                            
JAN BUSTAMANTE
Affiant

SUBSCRIBED AND SWORN to before me in the City of Davao this

th
30 day of April 2016, by JAN BUSTAMANTE, who has satisfactorily
proven her identity to me through his Voter’s ID issued by the COMELEC
bearing his photograph and signature and with VIN 1123-
06789J1214GJC10002-4, that he is the same person who personally signed
the foregoing document before me and acknowledged that he executed the
same.

WITNESS MY HAND AND SEAL this 2nd day of February 2020

in Davao City, Philippines.
 NOTARY PUBLIC
Doc. No. 59;
Page No. 12;
Book No. 01;
Series of 2020.