COMPLAINT BASED ON AN ACTIONABLE DOCUMENT (One Cause of Action)

(Caption)

COMPLAINT

COMES NOW the plaintiff, by the undersigned counsel, and to thisHonorable Court, respectfully alleges:

1. That the plaintiff is of legal age, Filipino citizen and resident of No.7 Agoo Street, Quezon City and the defendant is also of legal age, Filipino citizenand a resident of No. 19 Dagupan Street, Tondo, Manila where he may be served withsummons;

2. That on or about January 1, 1983, defendant obtained a loan of P20,000.00 from the plaintiff payable within 90 days from date of receipt at 12% per annum;

3. That said loan, now overdue, is evidenced by a promissory notesigned by the defendant, a copy of which is hereto attached as “annex A” and madepart of this complaint;

4. That despite repeated demands, both written and oral, defendanthas failed and refused to apply said loan;

5. That due to the unjust and unlawful act of the defendant to complywith the said demands, the plaintiff was compelled to institute this action engaging theservices of counsel in the amount of P1,000.00

WHEREFORE, it is respectfully prayed that judgment be rendered againstthe defendant to pay the plaintiff the sum of P20,000.00 plus interest of 12% from thedate of the instrument until full amount is payed and attorney’s fees in the amount of P1,000.00 and costs of the suit.

Other equitable reliefs are likewise prayed for.

 ___________________, 1991, Quezon City.

 ________________________ Attorney for Plaintiff 

 ________________________ Address

 

P.T.R. No.______ Date & Place of Issue______ IBP O.R. No._____ Date & Place of Issue_____ 

COMPLAINT (SEVERAL CAUSES OF ACTION)

Plaintiff Alleges:First Cause of Action

1. That the plaintiff is a resident of the City of Manila, and that defendant is aresident of 486 Tenesee, Malate, Manila where he may be served withsummons;

2. That on the 11th day of June, 1983, defendant executed and delivered to plaintiff a promissory note, in the following words and figures, to wit:

(insert copy of the promissory note or use as Annex)

3. That defendant has not paid promissory note, nor any part thereof or interestthereon;

As Second Cause of Action:

1. Plaintiff hereby incorporates the allegations of paragraph 1 of the first cause of action;

2. That on the 19th of August 1983, defendant executed and delivered to the plaintiff his promissory note in the following words and figures, to wit:

(insert copy of promissory note)

2. Same as paragraph 3 of the first cause of action)

WHEREFORE, it is respectfully prayed that judgment be rendered in favor of Plaintiff and against defendant for the sum of (the total amount of the promissory notes)with interest at the rate of six percentum per annum on each of the aforesaid notes, untilpaid; interest at the legal rate on the interest due from the time of the filing of thecomplaint and attorney’s fees plus costs.

PLAINTIFF, further prays for such other relief as this Honrable Court may deem just and equitable in the premises.

 

Manila, Philippines, October 10, 1987.

JOSE CRUZAttorney for the Plaintiff 

311 Regina Building, ManilaP.T.R. No.__ & IBP Receipt No.