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Republic of the Philippines

REGIONAL TRIAL COURT


12th Judicial Region
Branch __, Iligan City

CHOPCHUY LENDING CORPORATION


as represented by: SHELLY KABAITAN,
Plaintiff,
Civil Case No. 17-001

-versus- For: COLLECTION


OF SUM OF MONEY

VICON MANGUNGUTANG,
Defendant.
x------------------------------------------------------x

COMPLAINT
Comes now, petitioner, through counsel, unto this Honorable
Court, most respectfully avers that:
1. Plaintiff, Chopchuy Lending Corporation with business address
at Purok Unibersidad, Tibanga, Iligan City, is engaged in lending
money to its members;

2. Shelly Kabaitan is the authorized representative of the


corporation as evidenced by Certificate of Authority, herein
attached as Annex A;

3. Defendant is of legal age, Filipino, married and a resident of


Purok 2-C, Katipunan, Hinaplanon, Iligan City, where he could
be served with summons and other court processes;

4. On August 8, 2014, defendant contracted a loan in our


corporation in the amount of P350,000.00 with 6% interest per
annum and payable within three (3) years from the time the
amount was given to him as shown in the Loan Agreement,
attached hereto as Annex B;

5. As agreed upon, defendant will pay Php 10,305.00 to plaintiff


every 17th day of the month;
6. Defendant started paying on September 2014 and defaulted
from paying his obligations on January 2017 as reflected in
Official Receipts No. 789, 986 and 765 marked as Annex C, C-
1 and C-2;

7. On August 9, 2017, the obligation has matured, thus, the plaintiff


served Notice of Demand to the defendant three (3) times dated
February 1, 2017, March 10, 2017 and April 2017 as shown in
Annex D, D-1 and D-2, which however, were left
unheeded;

8. The continued refusal of defendant to settle his account


prompted the plaintiff to lodge a complaint with the barangay
officials of Barangay Tibanga, Iligan City and A Certificate to File
Action, copy of which is hereto attached as Annex E, was
subsequently issued for failure of the parties to come to an
Agreement.

9. Defendant, as of this date, defaulted in the payment of an


aggregate amount of Php 309,150.00; and

10. Notwithstanding plaintiffs repeated oral and written


demands, defendant failed and refused and still fails and refuses
to heed to the formers just and valid demands, leaving the
plaintiff no other recourse but to litigate and file this action.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed of this Honorable Court that after due hearing, judgment be
rendered against the defendant ordering the latter to pay the plaintiff
the following:

1. The amount of THREE HUNDRED NINE THOUSAND ONE-


HUNDRED FIFTY PESOS (Php 309,150.00) representing the
unpaid monthly instalments due under the Loan
Agreement dated August 8, 2014; and

2. Cost of suit.
Other reliefs just and equitable under the premises are
likewise prayed for.

ATTY. AIKO B. BIGMAC


Counsel for the Plaintiff
Room 116, Astro Bldg., Sunrise St., Tubd, Iligan City
Roll No. 76430
IBP No. 352980/1-2-17
MCLE Compliance No. 11-0004352
CERTIFICATION AND VERIFICATION OF NON-FORUM
SHOPPING