I.

PLEADINGS

Pleadings are filed in four (4) kinds of cases, namely: Civil Actions;
Provisional Remedies; Special Civil Actions; and Special Proceedings
A. MISCELLANEOUS CIVIL PLEADINGS
COMPLAINT BASED ON AN ACTIONABLE DOCUMENT (One Cause of
Action)
REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Manila, Branch 1

JUAN DELA CRUZ

Plaintiff,
Civil Case No.________
For Sum of Money

-versusPEDRO SANTOS
Defendant.
X------------------------------------------X

COMPLAINT
COMES NOW the plaintiff, by the undersigned counsel, and to this
Honorable 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
citizen and a resident of No. 19 Dagupan Street, Tondo, Manila where he may be
served with summons;
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

note
signed by the defendant, a copy of which is hereto attached as annex A and
made part of this complaint;
4.

That despite repeated demands, both written and oral,

defendant
has failed and refused to apply said loan;
5.

That due to the unjust and unlawful act of the defendant to

comply
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 attorneys fees
in the amount of P1,000.00 and costs of the suit.
Other equitable reliefs are likewise prayed for.
___________________, 1991, Quezon City.

JOSE CRUZ
Attorney for the Plaintiff
311 Regina Building, Manila
IBP No. ________, 1/2/2001, Pasig City
P.T.R. No. ______, 2/2/2001, Pasig City
Doc. No. _____;
Page No. ____;
Book No. _____
Series of 20___

COMPLAINT (SEVERAL CAUSES OF ACTION)

REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Manila, Branch 1

JUAN DELA CRUZ

Plaintiff,
Civil Case No.________
For Sum of Money

-versusPEDRO SANTOS
Defendant.
X------------------------------------------X

COMPLAINT
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 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
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 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, until paid; interest at the legal rate on the interest due from the
time of the filing of the complaint and attorneys 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
IBP No. ________, 1/2/2001, Pasig City
P.T.R. No. ______, 2/2/2001, Pasig City
Doc. No. _____;
Page No. ____;
Book No. _____
Series of 20___