Complaint Based on an Actionable Document (One Cause of Action)

COMPLAINT BASED ON AN ACTIONABLE DOCUMENT (One Cause of Action) (Caption) COMPLAINT COMES COMES NOW NOW the the plain plaintif tiff, f, by the under undersig signe ned d coun counsel sel,, and and to this this Honorable Court, respectfully alleges: 1. That That the the pla plain inti tiff ff is is of lega legall age, age, Fil Filip ipin ino o citi citize zen n and and res resid iden entt of  No.7 Agoo Street, Quezon City and the defendant is also of legal age, Filipino citizen and a resident of No. 19 Dagupan Street, Tondo, Manila where he may be served with summons; 2. That That on or abou aboutt Jan Janua uary ry 1, 1983 1983,, def defen enda dant nt obta obtain ined ed a loa loan n of  of  P20,000.00 from the plaintiff payable within 90 days from date of receipt at 12% per  annum; 3. That That sai said d loan loan,, now now over overdu due, e, is is evid eviden ence ced d by by a pro promi miss ssor ory y not note e signed by the defendant, a copy of which is hereto attached as “annex A” and made part of this complaint; 4. That That des despi pite te rep repea eate ted d dema demand nds, s, bot both h writ writte ten n and and oral oral,, defe defend ndan antt has failed and refused to apply said loan; 5. That That due due to the the unju unjust st and and unla unlawf wful ul act act of the the defe defend ndan antt to comp comply ly with the said demands, the plaintiff was compelled to institute this action engaging the services of counsel in the amount of P1,000.00 WHEREFORE, it is respectfully prayed that judgment be rendered against the defendant to pay the plaintiff the sum of P20,000.00 plus interest of 12% from the date 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 a resident of 486 Tenesee, Malate, Manila where he may be served with summons;

2.

That on the 11 th 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 interest thereon;

As Second Cause of Action:

1.

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

2.

That on the 19 th 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, until paid; interest at the legal rate on the interest due from the time of the filing of the complaint 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 CRUZ Attorney for the Plaintiff  311 Regina Building, Manila P.T.R. No.__ & IBP Receipt No.