Complaint for Sum of Money

REPUBLIC OF THE PHILIPPINES 6th Judicial Region Regional Trial Court Iloilo City

BC BC FIN FINNC NCE E N! LE LEN! N!IN IN" " CORPO CORPOR RT TION re#r re#re$e e$ente nted d %y &S' !INE IR!( Pre$ident

Plaintiff. -versus-

CI)IL CSE NO' For: Sum of money with Damages

&S' &ELNIE LEE

Defendant. x------------------------------------------------x

CO&PLINT

Plaintiff, through the undersigned counsel and to this Honorable ourt, res!ectfully aver that: ". #hat !lainti !laintiff ff is a finance and and lending lending cor!oratio cor!oration n duly organi$ organi$ed ed and existing under the %aws of the Phili!!ines, having its !rinci!al office at &' 'ldg, %o!e$ (aena St., (aro , )loilo ity* +. #hat defenda defendant nt is s. elanie elanie %ee, %ee, of legal age, age, Fili!ino Fili!ino citi$en citi$en and and residing at #abuc #abuc Suba, (aro, )loilo ity, where where she may be served with summons and other ourt !rocesses* . #hat on Se!tem Se!tember ber ", +/", +/", the defenda defendant nt obtained obtained a loan loan from the  !laintiff in the the sum of #hree Hundred Fifty #housand Pesos 0P/,///.//1 Phili!!ine urrency, with the following terms and conditions among others: a. #he !rinci!al !rinci!al loan loan obligation obligation shall shall be !ayable !ayable in #wo #wo 0+1 0+1 onths from time of execution of the agreement*  b. #he !rinci!al loan obligation obligation shall incur incur an interest of 23 !er month com!ounded* and c. #he loan loan was was to mature mature on " 4ovembe 4ovemberr +/". +/".

1

5. #hat the said loan is now overdue and des!ite demands made orally and in writing by the !laintiff, defendant6s s!ouse refused and failed to !ay the amount as evidenced by the Demand %etter send by the 'an76s %egal ounsel, dated December /", +/", !hotoco!y of which is hereto attached as &nnex 8&9 and made an integral !art hereof.

P R  * E R 

+HEREFORE, it is most res!ectfully !rayed of this Honorable ourt that after due hearing, udgment be rendered in favor of !laintiff and against the defendant in this manner.

".

;rdering the defendant to !ay !laintiff the amount of #hree Hundred Fifty #housand Pesos 0P/,///1 Phili!!ine urrency, with interest thereon at the rate of 23 !er month, com!ounded from Se!tember ",+/", and until the same is fully !aid* and

+.

;rdering the defendant to !ay the cost of this suit.

Plaintiff li7ewise !rays for such other and further relief or reliefs as this Honorable ourt may deem ust and e 4o.

Doc. 4o. BBBBBBBBBB  Page 4o. BBBBBBBBBB  'oo7 4o. BBBBBBBBBB  Series of +/"

Date: December 1, 2015

3

To:

Ms. Melanie Lee Brgy. Tabuc Suba  Jaro, Iloilo City DEMAND LETTER

Ms. Abucion, Good day! I, Anna Reyes, write to you today to remind you of the loan agreement we entered into on September 1, 2!1, in the amount of Php350,000,000 . "ccording to the term# of the promi##ory note you e$ecuted, payment would be made on or before November 30, 2015 . Con#ider thi# corre#pondence a# a formal demand for your compliance with the abo%ementioned loan agreement. &lea#e ma'e the payment of the out#tanding balance of &hp 3!,!!!.!! not later than one wee' from the receipt of thi# letter. (ou may pay the amount to me per#onally, or thru ban' depo#it at Banco De Oro Account No. 1234-56!-"0 un#er the name Anna $e%e& . I hope for your #wift compliance. If not, I regret to #ay that I would be forced to ta'e legal action in order to protect my own intere#t#. (ou may di#regard thi# letter if payment ha# been tendered at the time of receipt of the #ame.  Than' you.

)e#pectfully ,

ANNA B. REE!

*