Republic of the Philippines

8th Judicial Region

Regional Trial Court
Bulwagan ng Katarungan
Tacloban City

JULIA GOMEZ as his capacity

as the Manager of ABC LUMBER YARD
AND HARDWARE INC., CIVIL CASE NO:199
Plaintiff, FOR: COLLECTION OF
SUM OF MONEY
versus.

JULIO ENRIQUEZ as his capacity

as the Manager of XYZ
CONSTRUCTION COMPANY
Defendant.

COMPLAINT

COMES NOW, the plaintiff together with the undersigned counsel to

this most honorable court, most respectfully states that:

1. Plaintiff is the manager of a company duly organized and existing under

the Laws of the Philippines, having its principal office at 176-D Rizal
Extension, Tacloban City, Philippines. She could also be served with
summonses and other processes by the Honorable Court at the same
address;

2. Respondent is likewise a manager of a company duly organized and

existing under the Laws of the Philippines, having its principal office
at 188 Real Avenue, Tacloban City, Philippines where he could be
served with summonses and other processes by the Honorable Court;

3. Parties are capacitated to sue and be sued;

4. Defendant failed to pay the sum of Three Hundred and Thirty-Two

Thousand Pesos (Php 332,000.00) in construction materials which was
delivered on five different times;

5. The first delivery was on August 26, 2016 with an invoice number
CI337987 in an amount of 43,000.00;
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 6. The next delivery of the materials in the year 2016 was on October 6
with an invoice number CI239989 amounting to 63,000.00;

7. The following year, there are three more deliveries that has been made.
The first was on January 11 amounting to 123,000.00 and with an
invoice number of CI627392;

8. The succeeding delivery was on February 18 which has a total amount

of 93,000.00 and an invoice number of CI753951;

9. The last delivery was on June 28 which has the total amount of
10,000.00 and an invoice number of CI921974;

10.That as shown in the demand letter dated September 22, 2017, the
indebtedness of the defendant has become due and demandable on the
same date;

11.That despite plaintiff's repeated demands, both written and verbal,

defendant failed, neglected and refused to fulfill obligations without
just and valid grounds and prejudice of plaintiff, as evidenced by Annex
A Demand Letter;

12.That the plaintiff in order to enforce his rights and interests, has sought
the services of a legal counsel with attorneys fees amounting to Twenty
Thousand Pesos (PhP 20,000.00) and an appearance fee of Two
Thousand Pesos (PhP 2,000.00) per hearing as evidenced by Annex B
Contract for Legal Services;

WHEREFORE, PREMISES CONSIDERED, petitioner 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 Three Hundred and Thirty-Two Thousand Pesos (Php

332,000.00);

b. attorneys fees amounting to Twenty Thousand Pesos (Php

20,000.00) and an appearance fee of Two Thousand Pesos (Php
2,000.00) per hearing;

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for. Tacloban City, November 13,
2017.

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ATTY. ANA ROSE D. CINCO
Counsel for the Petitioner
ADC Law Office
JDC Bldg., Lopez Jaena St., Tacloban City
Phone Number: 09552151847
Email: cincoanarose@gmail.com

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