Complaint for Sum of Money - Yuri Trading

REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT 6th Judicial Region - oOo ISLAND MERCHANT CORPORATION Plaintiff,

CIVIL CASE NO.__________ NO.__________ FOR: SUM OF MONEY

- versus -

MARIA JANET LOYOLA Defendant. X------------------------------X COMPLAINT COMES NOW, the Plaintiff, by the undersigned counsel and unto this Honorable Court, most respectfully avers that:

1. The Plaintiff, ISLAND MERCHANT CORPORATION , is a corporation with business address at Murcia Road, Mansilingan Bacolod City, 6100. 2. Plaintiff may be served with copies of notices and orders of the Honorable Court at the office address of the undersigned undersigned counsel indicated below 3. The Defendant, MARIA JANET LOYOLA, still has a pending account with the Plaintiff in the principal amount of TWO HUNDERED NINETY-THREE THOUSAND NINETY-NINE PESOS AND FIFTY THREE CENTAVOS (P 293,099.53) as of November, 2013. A copy of the Statement of Account and Sales Invoice of said transactions are hereto attached as Annex respectively.  “A” and Annex “B”, respectively. 4. The Plaintiff has extended their forbearance to the Defendant for not being able to settle all accounts which the latter acknowledged and promised to pay starting August 8, 2011 as shown in her letter in response to the demand letter sent on August 2, 2011. A copy of the Defendant’s Reply Letter dated August 4, 2011 and the Demand Letter dated August 2, 2011 is hereto attached as Annex “C”  and Annex “D”, correspondingly. correspondingly.

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5. On August 31, 2012, a final Demand Letter was sent to the Defendant through the undersigned counsel. A copy of the Demand Letter is hereto attached as Annex “E”. 6. Despite repeated demands, the Defendant continued to fail in paying his accounts with the Plaintiff. PRAYER

WHEREFORE, premises considered, the Plaintiff respectfully prays of this Honorable Court that judgment be rendered against the Defendants as follows: a. Ordering Defendant to pay the Plaintiff the sum of TWO HUNDERED NINTY-THREE THOUSAND NINETY-NINE PESOS AND FIFTY THREE CENTAVOS (P 293,099.53) b. Ordering the Defendant to pay the Plaintiff the amount of P_____ as Attorney’ s Fees and Litigation Costs. Plaintiff further prays for such other relief and remedies as this Honorable Court may deem just and equitable under the premises.

Bacolod City, Philippines. December__, 2013.

PACIFICO M. MAGHARI, III Counsel for the Plaintiff AMEGO & Associates Law Office c/o Ground Floor, CIT Bldg., Lacson-LuzuriagaSts., Bacolod City PTR No. 5054090 B. C. Jan. 2, 2013 IBP No. 889816 B.C. Jan. 2, 2013 MCLE Compliance No. IV-0022024/9-24-13 SC ROLL NO. 44869

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VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, MANUEL T. PARROCO president IMC or SHIELA P. GOMEZ (Accounting and Control Manager) , of legal age, Filipino, married, and a resident of Bacolod City, Philippines, on oath, state that: 1. I am the president of ISLAND MERCHANT CORPORATION and I have caused the preparation of the foregoing Complaint; 2. I have read the same and the contents therein are true and correct to my own personal knowledge and based on authentic documents; 3. I have not initiated or commenced any similar action or proceeding involving the same issue and the same parties before any court, administrative body or in the Supreme Court, the Court of Appeals or other tribunal or agency; 4. Should I thereafter learn that a similar action or proceeding had been filed or is pending before any court, administrative body or in the Supreme Court , the Court of Appeals or other tribunal or agency, I hereby undertake to report such fact within (5)days from my knowledge thereof.

IN WITNESS WHEREOF, I have hereunto affixed my signature this ___ day of December, 2013 at the City of Bacolod, Philippines.

MANUEL T. PARROCO  Affiant 

SUBSCRIBED AND SWORN to before me this ____ day of December, 2013 in the City of Bacolod, Philippines, the affiant exhibiting to me his Government Issued ID No.___________, with his name, signature, and picture appearing thereon.

Doc. No. ____ Page No. ____ Book No. ____ Series of 2013. 3