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Complaint For Collection of Sum of Money

This document is a complaint filed in a civil court in the Philippines by Clifford Chatterley II, represented by Oliver Millors, against Juan de la Cruz and Crisostomo Ibarra for the collection of ₱500,000. The complaint alleges that the defendants borrowed ₱500,000 from the plaintiff in January 2022 and have failed to repay the loan after one year, causing damages. The plaintiff is seeking repayment of the loan, damages, and ownership of a land parcel pledged as loan collateral by one of the defendants. Oliver Millors verified the complaint and certified that it has not been forum shopped.

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Fatima Fayea Mejorada
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51 views3 pages

Complaint For Collection of Sum of Money

This document is a complaint filed in a civil court in the Philippines by Clifford Chatterley II, represented by Oliver Millors, against Juan de la Cruz and Crisostomo Ibarra for the collection of ₱500,000. The complaint alleges that the defendants borrowed ₱500,000 from the plaintiff in January 2022 and have failed to repay the loan after one year, causing damages. The plaintiff is seeking repayment of the loan, damages, and ownership of a land parcel pledged as loan collateral by one of the defendants. Oliver Millors verified the complaint and certified that it has not been forum shopped.

Uploaded by

Fatima Fayea Mejorada
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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Republic of the Philippines

______________TRIAL COURT
7th Judicial Region
Branch ____
___________

CLIFFORD CHATTERLEY II Civil Case No. 12345


represented by OLIVERS MILLORS For:
Plaintiff,
COLLECTION OF
- versus - SUM OF MONEY

JUAN DE LA CRUZ and


CRISOSTOMO IBARRA
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - -/

COMPLAINT

PLAINTIFF, through the undersigned Counsel, unto this


Honorable Court, most respectfully alleges:

1. That plaintiff is Filipino, of legal age and resident of Bool


district, Tagbilaran City, Bohol where they may be served with
notices and other processes, in addition to or in lieu of
counsel’s address, and in this case is represented by Oliver
Millors. Copy of the Special Power of Attorney executed by
Clifford Chatterley II is hereto attached as ANNEX “A”;

2. That defendant Juan dela Cruz is Filipino, of legal age and a


resident of Purok 2, San Jose, Talibon, Bohol where they may
be served with notices and other court processes;

3. That defendant Crisostomo Ibarra is Filipino of legal age and


a resident of Libertad, Baclayon, Bohol where they may be
served with notices and other court processes;

4. That the defendants are poker mates of the plaintiff since


December 1, 2021;

5. That on January 2, 2022, the two (2) defendants took out a


loan of money from the plaintiff in the amount of FIVE
HUNDRED THOUSAND PESOS (₱ 500,000.00) payable
within two (2) months at 10% per month. Copy of their Affidavit
of Acknowledgment of Debt is hereto attached as Annex “B”;
6. That to guarantee payment of the said loan, Juan dela Cruz
delivered unto the plaintiff Certificate of Title No. 56789
covering a parcel of land designated as Lot No. 100 situated
in Soom, Trinidad, Bohol with an assessed value of FORTY
THOUSAND PESOS (₱ 40,000.00);

7. That in alternative, or in lieu of payment of sum of money, the


plaintiff wants to appropriate immediately Lot No. 100 and
eventually consolidate his ownership thereto. Thus, the
defendants need to vacate the said land;

8. That until date (1 year after), the defendants, in a wanton and


stubborn refusal, failed to repay the said loan causing the
plaintiff mental anguish, sleepless nights and besmirch
reputation warranting the award of the following damages:

a. Moral damages in the amount of One Million Pesos


(₱1,000,000.00);
b. Liquidated damages in the amount of Six Hundred
Thousand Pesos (₱ 600,000.00); and
c. Other damages the court deems it proper to award such
as the exemplary damages;

PRAYER

WHEREFORE, premises considered, X X X

Other reliefs just and equitable under the premises are likewise
prayed for.

Tagbilaran City, Bohol, Philippines this 3rd day of February 2023.

ATTY. PEDRO PENDUKO


Counsel for the Plaintiff
Roll No. x x x, TIN x x x
PTR No. x x x, x x x Tagb. City
IBP No. x x x, x x x Bohol
MCLE Compliance No. VI- ____ until April 14, 2023)
Mezzanine Floor, x x x building, CPG Ave. Tagbilaran City
VERIFICATION AND
CERTIFICATION AGAINST FORUM SHOPPING

Republic of the Philippines)


CITY OF TAGBILARAN ) S.S.
x- - - - - - - - - - - - - - - - - - -/

I, OLIVERS MILLORS, Filipino, of legal age, and presently


residing in Tubigon, Bohol, Philippines, after having been duly sworn
to in accordance with law, do hereby declare and state:

1. That I am the duly authorized representative of the plaintiff in the above-


captioned case and that I have caused the preparation and filing of this
complaint;
2. That I have read the foregoing Petition and that the allegations therein are
true and correct based on our personal knowledge or based on authentic
documents;
3. That the pleading is not filed to harass, cause unnecessary delay, or
needlessly increase the cost of litigation;
4. That the factual allegations therein have evidentiary support or, if
specifically so identified, will likewise have evidentiary support after a
reasonable opportunity for discovery;
5. That I have not heretofore commenced any action of filed any claim
involving the same issues in any court, tribunal or quasi-judicial agency
and, to the best of our knowledge, no such other action or claim is pending
therein;
6. That if there is such a pending action or claim, a complete statement of the
present status thereof; and
7. That should I thereafter learn that the same or similar action or claim has
been filed or is pending, we shall report the fact within five (5) calendar
days therefrom to the court wherein our aforesaid Petition has been filed.

Affiants further sayeth naught.

IN WITNESS WHEREOF, I have hereunto affixed my signature


rd
this 3 day of February 2023 at Tagbilaran City, Bohol, Philippines.

OLIVERS MILLORS
Affiant
Driver’s License No. 123456-A

SUBSCRIBED AND SWORN TO before me this 3rd day of


February 2023 at Tagbilaran City, Bohol, Philippines.

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