LEGAL FORMS: COMPLAINT

Question 1

Complaint Header

Answer 1

Republic of the Philippines
First Judicial Region
RTC/MTC
Branch
Baguio City, Philippines

Question 2

Complaint Header Content - Civil Case

Answer 2

AAA, Plaintiff
-versus-
BBB, Plaintiff

CIVIL CASE NO. _____
Collection of a sum of money

Question 3

Complaint - Introductory Part

Answer 3

Plaintiff, by and through the undersigned counsel, aver and state that:

Plaintiff, AAA, Personal Circumstances, where he can be served with notices and other court processes;

Defendant, BBB, PC, where he can be served with summons and other court processes

Question 4

Allegation/claims for Collection of Sum of Money

Answer 4

1. On January 1 2024, BBB borrowed the amount of 10M from the Plaintiff AAA
2. The amount of 10M borrowed by BBB is evidenced by a Promissory Note dated January 1, 2024, a copy of the Promissory Note is hereto attached marked as ANNEX A”
3. In that Promissory Note, it was stated that the debt of 10M shall be due and demandable on February 14 2024, without demand
4. On Feb 15 2024, AAA issued a Demand Letter addressed to BBB, which BBB received on (DATE), ** a copy of the Demand Letter is hereto attached and marked as ANNEX “B” **
5. In that Demand Letter, it was stated that the defendant is given 5 days from receipt thereof to pay the debt, otherwise the proper case shall be filed against him;
6. Despite receipt and the lapse of the 5-day period; BBB still failed and refused to pay his debt in the amount of 10M

Question 5

Presentation of Evidence

Answer 5

1. To prove the allegations in the Complaint, the Plaintiff will testify in this case, a copy of his Judicial Affidavit is hereby attached. A summary of his testimony will be as follows

HEADER : NAME OF WITNESS AND NATURE OF THEIR TESTIMONY

(NAKA TABLE)
a. NAME b.NATURE/PURPOSE OF TESTIMONY

2. During trial, the following /documentary/ evidence shall be presented and identified:

HEADER: DOCUMENTARY EVIDENCE AND THEIR PURPOSE

a. Exhibit b. Nature of Document c. Purpose

Question 6

Justification for compensation

Answer 6

1. Because of Defendant’s failure to pay the debt which became due and demandable, the Plaintiff was forced to engage the services of Atty. Macalino and was obliged to pay XXX
2. Due to the non-payment of the debt, the plaintiff suffered mental anguish, sleepless nights and serious anxiety that if quantified, would amount to XXX Pesos

Question 7

PRAYER

Answer 7

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court, and after due notice and hearing that judgment be rendered in favor of the Plaintiff and:

1. To order the Defendant to perform his principal obligation
2. To order the Defendant to pay the debt in the amount of XXX
3. To Pay Fifty Thousand Pesos (P50,000.00) as moral damages;
4. To pay Fifty Thousand Pesos (P50,000) as Attorney’s fees

Plaintiff further prays for such other reliefs and remedies just and equitable under the circumstances

Question 8

2nd to Last Part

Answer 8

This 1st Day of January 2026, in Baguio City Philippines

MACALINO LAW OFFICES

Counsel for Plaintiff by:

ATTY. FOX

Roll
PTR
IBP
MCLE
CP No.
Email

Question 9

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

Answer 9

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, AAA, Personal Circumstances, after having been sworn to in accordance with law, depose and state that:

1. I am the plaintiff in the above-entitled case for (NAME NG CASE) filed before RTC, Branch, Baguio City, PH against DEFENDANT
2. I have caused the preparation of the foregoing
3. I have read the allegations therein contained and that:a. The same are true and correct of my own personal knowledge or based on authentic records;
   b. The pleading is not filed to harass, cause unnecessary delay or needlessly increase the cost of litigation; and
   c. The factual allegations therein have evidentiary support after reasonable opportunity for discovery;
4. I have not theretofore commenced any action or filed any claim involving the same issue in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such other action or claim is pending therein , and should I learn that the same or similar action or claim has been filed or is pending, I shall report that fact within 5 days therefrom the the office or court where this complaint has been filed