Complaint

REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT

Sixth Judicial Region
Branch 32
Iloilo City
ISABELLE LOPEZ CIVIL CASE NO. 21-0123

Plaintiff, For: Collection of sum of money
-versus-
ELIAS ORTEGA
Defendant.
x---------------------------x
COMPLAINT
COMES NOW, PLAINTIFF, through the undersigned counsel

and unto this Honorable Court, most respectfully states that:
PERSONAL CIRCUMSTANCES
1. Plaintiff ISABELLE LOPEZ is of legal age, single, Filipino,

and a resident of Brgy. Airport Mandurriao, Iloilo City,
Philippines where it may be served with summons and other
processes of the Honorable Court;
2. Defendant ELIAS ORTEGA is of legal age, married, Filipino,

and a resident of Brgy. Bulilao, Mandurriao, Iloilo City,
Philippines where he may be served with orders, notices,
and other legal processes of this Honorable Court;
3. On the morning of January 21, 2020, defendant Ortega

borrowed an amount with a total of FIVE HUNDRED
THOUSAND PESOS (500,000) from plaintiff Lopez.
Defendant promised to pay this amount in full on or before
that expiration of the 12 months given by the plaintiff;
4. As part of their agreement, the parties agreed that the
principal amount of FIVE HUNDRED THOUSAND PESOS
and the 2% interest amounting to TEN THOUSAND PESOS
(10,000) shall be payable upon the demand of herein
plaintiff. (A copy of the promissory note executed by the
herein parties is attached hereto and made an integral part
hereof and marked as Annex “A”);
5. That as shown in the attached promissory note, the

indebtedness of the defendant has become due and
demandable on January 21, 2021;
6. Despite plaintiff’s repeated demands, both written and verbal,

defendant failed and neglected to fulfill obligations without
valid grounds to the continued prejudice of plaintiff, as
evidenced by Annex “B” – Demand Letters;
7. To enforce its rights and interests, plaintiff sought the

services of counsel and incurred Sixty Thousand Pesos (Php
60,000.00) as acceptance fee and Five Thousand Pesos
(Php 5,000.00) as appearance fee for every hearing as
evidenced by Annex “C”- Contract for Legal Services;
8. The plaintiff has paid for litigation expenses amounting to

Thirty Thousand Pesos (Php 30,000) as evidenced by Annex
“D”- Official Reciept;
9. The plaintiff has suffered moral damages at the sum

discretion of the Honorable Court;
PRAYER
WHEREFORE it is respectfully prayed before the Honorable

Court to render decision in favor of the plaintiff and order the
defendant to pay the following;
a. the sum of FIVE HUNDRED THOUSAND PESOS (Php 500,
000) plus interest at the rate of two percent (2%) per month as
stipulated in the promissory note;
b. moral damages, exemplary damages at the sum discretion of

the court;
c. attorney’s fee amounting to Sixty Thousand Pesos (Php

60,000.00) as acceptance fee and Five Thousand Pesos (Php
5,000.00) as appearance fee for every hearing;
d. litigation expenses amounting to Thirty Thousand Pesos (Php

30,000).
Plaintiff prays for such other and further reliefs as may be deemed
just and equitable under the premises.
Iloilo City for Iloilo City. 25 April 2021.
GANZON LAW OFFICE

Counsel for the Plaintiff
2 Flr., St. Elizabeth Building
nd
Gen. Luna St., Iloilo City
By:
ATTY. CONCEPCION GANZON

[email protected]
0912-3456897
IBP No. 011268 (Lifetime), 06/13/19, Pasig City
PTR No. 1241986, 01/12/2020, Iloilo City
Roll of Attorneys No. 541123
MCLE Compliance No. VI-0014856, 08/26/19
VERIFICATION and CERTIFICATION
OF NON-FORUM SHOPPING
I, ISABELLE A. LOPEZ, of legal age, single, Filipino, and a

resident of Brgy. Airport, Mandurriao, Iloilo City, Philippines, after
having been duly sworn to in accordance with law hereby depose and
state that:
I am the Plaintiff in the above-entitled case;
I caused the foregoing “COMPLAINT” to be prepared;
The allegations in the pleading are true and correct based on
my personal knowledge and authentic documents;
The pleading is not filed to harass, cause any unnecessary
delay, or needlessly increase the cost of litigation;
The factual allegations therein have evidentiary support or, if
specifically so identified, will likewise have evidentiary support after a
reasonable opportunity for discovery;
I not theretofore commenced any action or filed any claim
involving the same issues in any court, tribunal or quasi-judicial
agency and, to the best of my knowledge, no such other action or
claim is pending therein. If there is such other pending action or
claim, a complete statement of the present status thereof; and
If I should thereafter learn that the same or similar action or
claim has been filed or is pending, I shall report that fact within five
(5) calendar days therefrom to the court wherein my aforesaid
complaint or initiatory pleading has been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this 24 th

day of April 2021 at Iloilo City, Philippines.
ISABELLE A. LOPEZ
PRC No. 002324
The affiant whose name and personal circumstances are stated

above-personally appeared before me this 24 th day of April 2021 in
the City of Iloilo presented the foregoing Verification and Certification,
signed the same in my presence and affirmed under oath to the
correctness of the contents or allegations of the same.
The affiant is personally known to me and he exhibited to me
his competent evidence of identity appearing below her name.
Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2021.

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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

ISABELLE LOPEZ CIVIL CASE NO. 21-0123

COMES NOW, PLAINTIFF, through the undersigned counsel

1. Plaintiff ISABELLE LOPEZ is of legal age, single, Filipino,

2. Defendant ELIAS ORTEGA is of legal age, married, Filipino,

3. On the morning of January 21, 2020, defendant Ortega

5. That as shown in the attached promissory note, the

6. Despite plaintiff’s repeated demands, both written and verbal,

7. To enforce its rights and interests, plaintiff sought the

8. The plaintiff has paid for litigation expenses amounting to

9. The plaintiff has suffered moral damages at the sum

WHEREFORE it is respectfully prayed before the Honorable

b. moral damages, exemplary damages at the sum discretion of

c. attorney’s fee amounting to Sixty Thousand Pesos (Php

d. litigation expenses amounting to Thirty Thousand Pesos (Php

Iloilo City for Iloilo City. 25 April 2021.

GANZON LAW OFFICE

Gen. Luna St., Iloilo City

ATTY. CONCEPCION GANZON

I, ISABELLE A. LOPEZ, of legal age, single, Filipino, and a

IN WITNESS WHEREOF, I have hereunto set my hand this 24 th

The affiant whose name and personal circumstances are stated

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