REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF MANILA

1st JUDICIAL REGION
BRANCH 16
MANILA

ALEXANDER D. GREATEST,
Plaintiff.

CIVIL CASE NO. ____

---versus --- For: Collection of Sum of Money

JUAN P. MASIPAG
Defendant.

x---------------------------------x

COMPLAINT
Plaintiff, thru the undersigned counsel, and unto this Honorable Court, respectfully avers the following:
1. That plaintiff, Alexander D. greatest is a resident of No. 112 Liberty Street, Mandaluyong City; while
defendant, Juan P. Masipag is a resident of No. 2, Juan de la Cruz Street, Sampaloc, Manila, where they
may be served with summons;

2. Than on January 13, 2007, defendant Masipag borrowed from the plaintiff the sum of ONE MILLION
PESOS (Php 1,000,000.00) with interest at the rate of TWELVE (12%) percent per annum and in case of
non-payment at maturity as evidenced by a promissory note executed on January 13, 2007, hereto
attached as Annex A and made an integral part hereof by refence;

3. That of said principal obligation which became due and demandable on January 14, 2009, defendant has
not made any payment, the total amount due on the loan account is ONE MILLION NINE HUNDRED
SIXTY THOUSAND PESOS (Php 1,960,000.00), including interests;

4. That defendants have failed and refused, and still fail and refuse to pay the same or any part thereof,
notwithstanding the repeated and final demands from plaintiff, herein attached as Annexes B, C and
D and made integral parts hereof;

5. That by reason of unjustified refusal to satisfy plaintiffs plainly valid, just and demandable claim, the
latter was compelled to engage the services of counsel and incur litigation expenses in the sum of
SEVENTY-FIVE THOUSAND PESOS (Php 75,000.00) attorneys fees, and a fee of THREE
THOUSAND PESOS P 3,000.00. for every appearance in court;
WHEREFORE, in view of the foregoing, plaintiff respectfully prays to this Honorable Court, that after due
hearing, judgment be rendered in favor of the plaintiff and against the defendants:
1. That they be ordered to pay the plaintiff the sum of ONE MILLION NINE HUNDRED SIXTY
THOUSANDPESOS ONLY (Php 1,960,000.00), which includes the principal amount and interests from
January 3, 2008 computed as agreed upon by the partiesin the promissory note;

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 2. That they be ordered to pay all the legal fees including attorneys fees and appearance fee for every
hearing in court.
Plaintiff further prays for such other relief as the Honorable Court may deem just and equitable in the
premises.

Iloilo City, May 10, 2017.

NONITO Q. PASUELO, JR.

Counsel for Plaintiff
Suite 007, 2nd Floor, Pasuelo Tower
MEGAWORLD, Iloilo City
Roll No. 66199
IBP No. 011 Lifetime
PTR No. 70 - 1/2/16 Iloilo
MCLE Compliance IV No. 001234
Issued on January 12, 2015

VERIFICATION AND CERTIFICATION

I, ALEXANDER D. GREATEST of legal age residing at No. 112 Liberty Street, Tondo, Manila, after being
sworn to in accordance with law, deposes and says that:
1. I am the Plaintiff in the above-titled case;

2. The facts stated in the above complaint are true and correct to the best of my knowledge and authentic
records;

3. I have not commenced any action or filed any claim involving the same issues in any court, tribunal or
quasi-judicial agency and, to the best of my knowledge, no such other action or claim is pending in them;
and

4. If I should learn that the same or similar action or claim has been filed or is pending after its filing, I
shall report that fact within five (5) days from notice to the court or where the complaint or initiatory
pleading has been filed.
Signed this 8th of May, 2017, in Iloilo City, Philippines.

ALEXANDER D. GREATEST
Affiant

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 SUBSCRIBED and sworn to before me, this _10th_ day of January, 2017, in the City of Iloilo with SSS No.
07-2157659-3 issued on June 16, 2000 in Iloilo City, Philippines. I hereby certify that I have examined the affiant.

ROXAN R. LABIS
Notary Public
Roll of Attorney 108831
IBP No. 857218, 01/03/16, Iloilo City
PTR No. 1316719, 01/03/16, Iloilo City
MCLE COMP. NO. IV-0005397, 03/03/16

Doc. No. _______;

Page No. _______;
Book No. _______;
Series of 20 _____.

ANNEX A

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ANNEXB

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ANNEXC

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ANNEXD

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