complaint sum of money

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Republic of the Philippines National Capital Judicial RegionMunicipal Trial CourtQuezon City, Branch 28

COMPLAINT AFFIDAVIT

Plaintiff, by counsel, respectfully states that:

1. Plaintiff, Merriam Acosta, is a Filipino citizen, of legal age, married, and residing at No. 1 Matapat St., cor. V. Luna Road, Diliman, Quezon City, where she may be served with court processes, motions, and decision; 2. Defendant, Mercedes Santiago, is a Filipino citizen, of legal age, and residing at No. 66 Maginhawa St., Teachers Village, Quezon City where he may be served with summons and other court processes; 3. On 24 April 2014, the defendant obtained a loan from the plaintiff in the sum of Fifty Thousand Pesos (PhP 50,000.00) to be fully paid on 24 May 2014 as evidenced by a Promissory Note dated 24 April 2014, (photocopy of which is hereto attached as Annex A) which reads as follows:

Quezon City, Philippines24 April 2014

I promise to pay Merriam Acosta the sum of Fifty Thousand Pesos (PhP 50,000.00) or order within 30 days from this date.

Mercedes Santiago

4. The 30-day period had elapsed, and despite demands made orally and in writing (attached as Annex B) by the plaintiff, defendant refused and faield to pay the amount in the promissory note;5. That due to the unjust refusal of defendant to comply with the demands, plaintiff was compelled to file the instant action engaging the services of counsel in the amount of Ten Thousand Pesos PhP 10,000.00.

PRAYERWHEREFORE, plaintiff respectfully prays for judgment in his favor through a decision directing the defendant:

a. To pay plaintiff the sum of Fifty Thousand Pesos (PhP 50,000.00);b. Attorneys Fees in the amount of Ten Thousand Pesos (PhP 10,000.00);c. The cost of this suit.

Other just and equitable relief are also prayed for. Quezon City, 16 January 2015.

ATTY. HAZEL JOY T. GALAMAY-Counsel for the Plaintiff-