Republic of the Philippines
MUNICIPAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
QUEZON CITY
BRANCH 76
LUTGARDA PEARL JOY
SORIANO,
Plaintiff,
vs CIVIL CASE NO. 12271994
Collection of Sum of Money
DONNA MAE DUMALIANG,
Defendant.
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COMPLAINT
PLAINTIFF LUTGARDA PEARL JOY SORIANO, by counsel, to
this Honorable Court, respectfully states that:
1. Plaintiff, Lutgarda Pearl Joy Soriano, 24 years old, Filipino, single,
residing at #3 Koppel Street, Filinvest 2. Batasan Hills, Quezon City;
2. Defendant, Donna Mae Dumaliang, 23 years old, Filipino, single,
residing at #438 San Diego Street, Sampaloc Manila, where they may
be served with summons and other processes of this Honorable
Court;
3. That on October 1, 2016 defendant borrowed from the plaintiff a
sum of money amounting to Five Hundred Thousand Pesos
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(PhP500,000.00) with an agreed interest of twelve percent (12%) per
annum as evidenced by a promissory note dated October 15, 2016
herein attached as Annex “A” and form an integral part of this
complaint;
4. That as shown in the attached promissory note, the indebtedness
of the defendant has become due and demandable on October 15,
2017;
5. That plaintiff writes a demand letter giving fifteen (15) days for
defendant to comply with her obligation. Demand letter herein
attached as Annex “B” and form an integral part of this complaint;
6. That despite plaintiff's repeated demands, both written and verbal,
defendant failed, neglected and refused to fulfill obligations without
just and valid grounds to the continued damage and prejudice of
plaintiff;
7. That the plaintiff in order to enforce her rights and interests, has
sought the services of a legal counsel with attorney’s fees amounting
to One Hundred Fifty Thousand Pesos (Php 150,000.00) and an
appearance fee of Three Thousand Pesos (PhP 3,000.00) per
hearing as evidenced by Annex “C” – Contract for Legal Services;
8. That the plaintiff has paid for litigation expenses amounting to
Thirty Thousand Pesos (PhP 30,000.00) as evidenced by Annex “D”
– Official Receipt;
9. That the plaintiff has suffered moral damages at the sum discretion
of the Honorable Court;
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WHEREFORE, premises considered, it is hereby respectfully
prayed before the Honorable Court to render decision in favor of the
plaintiff and order the defendant to pay the following:
a. the sum of Five Hundred Thousand Pesos (P 500,000.00)
plus interest at the rate of twelve percent (12%) per annual
as stipulated in the promissory note;
b. moral damages, exemplary damages at the sum discretion
of the court;
c. attorney’s fees amounting to One Hundred Fifty Thousand
Pesos (PhP 150,000.00) and an appearance fee of Three
Thousand Pesos (PhP 3,000.00) per hearing;
d. litigation expenses amounting to Thirty Thousand Pesos
(PhP 30,000.00).
Other reliefs and remedies deemed just and equitable under
the foregoing premises are likewise prayed for.
Quezon City, October 25, 2017
ATTY. KARINA BASSIG
Counsel for Petitioner
Bassig-Soriano Law Offices
Roll of Attorneys No. 12345
PTR NO. 678911, 12/30/16, Manila
IBP NO. 121314, 12/30/16, Manila
MCLE Comp. No. IV-000888, 12/30/16
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VERIFICATION/CERTIFICATION
I, Lutgarda Pearl Joy Soriano, 24 years old, Filipino, single and
resident of #3 Koppel Street, Filinvest 2, Batasan Hills, Quezon City,
after having been sworn in accordance with law, hereby depose and
state:
1. That I am the complainant in the above-entitled case;
2. That I have caused the preparation of the foregoing Complaint;
3. That I have read and understood all the allegations contained
therein, and the same is true and correct of my own personal
knowledge and based on authentic records;
4. That I certify under oath that I have not commenced any other
action or proceeding which is pending in the Supreme Court, the
Court of Appeals, or any other tribunal or agency. To the best of my
knowledge, no such action or proceeding is pending in the Supreme
Court, the Court of Appeals, or any other tribunal or agency;
5. I likewise undertake that if there is any such action or
proceeding which is either pending or may have been terminated, I
will state the status thereof. If I should thereafter learn that the similar
action or proceedings has been filed or is pending before the
Supreme Court, the Court of Appeals, or any other tribunal or agency.
I will undertake to report the fact within five days therefrom to the
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Court or agency wherein the original pleadings an sworn certification
contemplated in Administrative Circular No. 04-94 February 8, 1994.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
27TH day of June 2019 in Quezon City, Philippines.
Affiant
Driver’s License No. AO1-88-0234
Expiry Date: 2020-06-27
SSS ID No. 33-889898
SUBSCRIBED AND SWORN TO BEFORE ME, a Notary Public
for and in the City of Manila, affiant personally appeared having
exhibited to me her Driver’s License which details are indicated below
her name and signature.
WITNESS MY HAND AND SEAL this 1st day of July 2019 in the
City of Malolos, Bulacan.
ATTY. RUTH DULATAS
NOTARY PUBLIC
Roll of Attorneys No. 12345
PTR NO. 6789, 08/28/15, Manila
IBP NO. 23456, 08/28/15, Manila
MCLE Comp. No. IV-000888 08/2715
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2017
