(1) Nena Rose Z. Bugrong filed a complaint against Roshan Lanes Tagalibod for collection of a sum of P50,000.50 that was obtained as a loan on June 21, 2013 and was due for payment on June 21, 2014. (2) Tagalibod only paid P1,000.50 of the principal and failed to pay the remaining balance despite demands, owing P49,000 with 30% annual interest and penalty from the due date. (3) Bugrong is seeking a court order for Tagalibod to pay the remaining balance, attorney's fees, and litigation costs.
(1) Nena Rose Z. Bugrong filed a complaint against Roshan Lanes Tagalibod for collection of a sum of P50,000.50 that was obtained as a loan on June 21, 2013 and was due for payment on June 21, 2014. (2) Tagalibod only paid P1,000.50 of the principal and failed to pay the remaining balance despite demands, owing P49,000 with 30% annual interest and penalty from the due date. (3) Bugrong is seeking a court order for Tagalibod to pay the remaining balance, attorney's fees, and litigation costs.
Original Description:
Complaint affidavit, collection of sum of money sample
(1) Nena Rose Z. Bugrong filed a complaint against Roshan Lanes Tagalibod for collection of a sum of P50,000.50 that was obtained as a loan on June 21, 2013 and was due for payment on June 21, 2014. (2) Tagalibod only paid P1,000.50 of the principal and failed to pay the remaining balance despite demands, owing P49,000 with 30% annual interest and penalty from the due date. (3) Bugrong is seeking a court order for Tagalibod to pay the remaining balance, attorney's fees, and litigation costs.
(1) Nena Rose Z. Bugrong filed a complaint against Roshan Lanes Tagalibod for collection of a sum of P50,000.50 that was obtained as a loan on June 21, 2013 and was due for payment on June 21, 2014. (2) Tagalibod only paid P1,000.50 of the principal and failed to pay the remaining balance despite demands, owing P49,000 with 30% annual interest and penalty from the due date. (3) Bugrong is seeking a court order for Tagalibod to pay the remaining balance, attorney's fees, and litigation costs.
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REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
SIXTH JUDICIAL REGION BACOLOD CITY, BRANCH IX NENA ROSE Z. BUGRONG Plaintif versus NO. 12345566
CIVIL CASE FOR: Collection of a Sum of Money
ROSHAN LANES TAGALIBOD
Defendant xx COMPLAINT PLAINTIFF, thru the undersigned counsel, unto this Honorable Court respectfully alleges: 1. The Plantif is of legal age, Filipino, single and with residence at #11 Kabukiran Street, Brgy. San Birhen, Bacolod City; 2. That the defendant ROSHAN LANES TAGALIBOD is likewise of legal age, Filipino, single and with a residence at Blk 5, lot 5, Bangga Cegasco, Purok Pahanocoy, Brgy. Sumag, Bacolod City, where she could be served with summons and other processes of the court; 3. That on June 21, 2013, the defendant obtained a loan from the plaintif in the sum of Fifty Thousand Pesos and Fifty Centavos (P50,000.50) to be fully paid on its due date which is on June 21, 2014 as evidenced by a promissory note dated June 21, 2013, a photocopy of which is hereto attached as Annex A; 4. That defendant was able to pay only the amount of P1,000.50 from the principal amount despite the lapse of the period to pay the loan, defendant failed to pay her the total obligation thereby entitling the plaintif to be paid of the 1
unpaid principal in addition to the agreed 30% per annuity
by way of interest and 30% per annum by way of penalty, photocopy of statement of account is hereto attached as Annex B and made an integral part hereof; 5. That said loan now long overdue despite of repeated demands and she failed and refused to pay the same as evidenced by the Demand Letters send by the Plaintif, photocopy of which is hereto attached as Annex C and made an integral part hereof; 6. The repeated demands were made for the defendant to pay her obligations but she failed to pay. WHEREFORE, Plaintif respectfully prays for judgment in its favor through a decision directing the defendant: a. To pay Plaintif the sum of Forty Seven Thousand Five Hundred Pesos (P49,000.00 with interest at 30% and 30% as penalty from June 21, 2014 until the full amount is paid; b. Attorneys Fees at 10% of the principal amount; c. the cost of the suit Other just and equitable reliefs are also prayed for. Bacolod City, Negros Occidental, February 25, 2015
ATTY. CARLO FRANCES E. CABALLERO
Counsel for the plaintif NOBC Bldg., Gatuslao St., Bacolod City Attorneys Roll No. 098532 IBP No. 24525-01/03/15-Bacolod PTR No. 53532- 01/03/15-Bacolod MCLE Compliance No. IV-0012345 November 17, 2014
VERIFICATION AND CERTIFICATION OF NON-FORUM
SHOPPING I, NENA ROSE Z. BUGRONG, of legal age, after having been duly sworn in accordance with law, depose and state that: 1. I am a plaintif in the foregoing Complaint for Sum of Money; 2. I caused the preparation of the Complaint, which I have fully read and understand; 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 of copies of documents and records in my possession; 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.
NENA ROSE Z.BUGRONG
Affiant SUBSCRIBED AND SWORN to before me this 25 day of February 2015 at Bacolod City, affiant exhibiting to me his Community Tax Certificate No. 12345677 issued on January 3, 2015 at Bacolod City. th
ATTY. CARLO FRANCES E. CABALLERO
NOBC Bldg., Gatuslao St., Bacolod City Attorneys Roll No. 098532 3
IBP No. 24525-01/03/15-Bacolod
PTR No. 53532- 01/03/15-Bacolod MCLE Compliance No. IV-0012345 November 17, 2014 Doc. No. 22 Page No. 32 Book No. 01 Series of 2015