REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

City of Zamboanga
Branch ____

BENSAUD O. DEGUSMAN,
Plaintiff
-versus-

CIVIL CASE No.

For: Sum of Money with

JORDACHE L. RAMOS
Defendant,
x-x
COMPLAINT

avers:

COMES NOW, the plaintiff, through counsel, and unto this Honourable Court, most respectfully

1. That plaintiff is of legal age, Filipino, with postal address at Tumaga, Zamboanga City;
2. That defendant Jordache L. Ramos is of legal age, Filipino with postal address at Tumaga,
Zamboanga City, where he may be served with summons and other processes by this Honorable
Court;
3. That sometime in December 2014, defendant obtained a loan from the plaintiff in the amount
of P100,000.00, with the promise to pay it within six (6) months from the said date, with an agreed
interest of 2.75 percent per month as evidenced by a promissory note which is attached as Annex A
hereof.
4. That after the lapse of the period agreed upon, defendant failed to pay the amount of the
loan and its interest;
5. The plaintiff through his counsel sent a demand letter on ______, _______, ________ and
_______ to the defendant demanding for the payment of the loaned amount of P100,000.00 plus
interest of 2.75% per month for 6 months. Copy of the demand letters personally served to the
defendants is hereto attached as Annex B hereof.
6. That despite repeated demands orally and in writing, defendants refused and continuously
failed to pay the amount of P100,000.00 and its interest to the damage and prejudice of the plaintiff.
7. That as a result of the unwarranted and unjustified refusal of the defendants to pay the
plaintiff the said amount of interest, he suffered sleepless nights, serious anxiety in which he should be
awarded the amount of P100,000.00 as moral damages and to set an example to the public, plaintiff
should be awarded exemplary damages in the amount of P100,000.00
WHEREFORE, premises considered, it is most respectfully prayed unto this Honourable Court
that, after hearing, judgment be rendered as follows:
1.Ordering the defendant, to pay the plaintiff the amount of P100,000.00 representing the
loaned amount;

2. Ordering the defendant to pay the plaintiff an interest of 5% of the total amount of
P100,000.00 for six (6) months as agreed upon.;
3.Ordering the defendant to pay the plaintiff the amount of P100,000 as moral damages, and
P100,000.00 as exemplary damages;
4. Ordering the defendant to pay the cost of suit.
Zamboanga City, November 1, 2015

CABATO CARDENAS DEGUSMAN

GARCIA AND GENERAL LAW OFFICE
Counsel for the plaintiff
4th Floor, Sauras Building,
La Purisima Street, Zone IV,
Zamboanga City

By:
MA CHERYL P. CARDENAS
IBP No. 6100083/2-5-15
PTR No. 2608301283012/10-22-15/Zamboanga
Roll No 54547

VERIFICATION AND CERTIFICATION AGAINST

FORUM SHOPPING
REPUBLIC OF THE PHILIPPINES
CITY OF ZAMBOANGA

)
) S.S.

I, BENSAUD DEGUSMAN, of legal age, Filipino citizen, single and resident of Tumaga,
Zamboanga City, after having been duly sworn to in accordance with law do herby depose and say:
1 That I am the Plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing Complaint and have read the allegations
contained therein;
3. The allegations in the said complaint are true and correct of my own knowledge and
authentic records;
4. I hereby certify that I have not commence any other action or proceeding involving the same
issues the Supreme Court, Court of Appeals, or any other tribunal or agency;
5. That if I should thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, Court of Appeals, or any other tribunal agency, I hereby undertake
to report that fact within five (5) days therefrom to the court or agency wherein the original pleading
and sworn certification contemplated herein have been filed;
6. I executed this verificationcertification to attest tot eh truth of the