Republic of the Philippines

REGIONAL TRIAL COURT

Branch 23
General Santos City

BEATRICE ALONDO,
Plaintiff,

CIVIL CASE NO. 000711

-versus- For: Specific Performance

JULIE BARETT,
Defendant
x-----------------------------------x

COMPLAINT

COMES NOW, plaintiff, Beatrice Alondo, by counsel, and unto this

Honorable Court, most respectfully avers:

1. That plaintiff Beatrice Alondo, is 29 years old, single, Filipino,

and a resident of 143 Iniwan St., Brgy. Naloko, General
Santos City;

2. That defendant Julie Barett, is 32 years old, single, Filipino,

and a resident of Agaw St, Brgy. Mapanakit, General Santos
City;

3. That plaintiff is a jewelry collector for almost two (2) years.

That on May 3, 2019, due from referrals of other collectors,
the plaintiff meet up with herein defendant together with one
Emerald Undermoon;
 4. That the defendant owns a 24-karat gold necklace with
diamond pendant. Plaintiff enamoured by the said necklace
immediately asked for the price.

5. After a week, plaintiff contacted Emerald Undermoon, the

agent of defendant, signifying her intention to purchase the
said jewelry in the amount of Five Hundred Thousand Pesos
(P500,000.00) which is the selling price;

6. A deed of absolute sale duly signed by the agent was

thereafter executed in favour of the plaintiff with a provision
that the necklace shall be delivered upon encashment of the
check on May 15, 2019. The deed of absolute sale was
hereto attached as Annex “A”;

7. That on the same date, plaintiff issued a check in the amount

of Five Hundred Thousand Pesos (P500,000.00) as payment
for the said necklace.

8. That after receiving bank statement showing that the amount

was debited, still there was no necklace delivered to the
plaintiff. The bank statement was hereto attached as Annex
“B”;

9. That despite the service of demand letter which was

repeated by oral demands, the defendant failed and still
refused to deliver said jewelry;

10. That by reason of failure of the defendant to comply with

the delivery, the plaintiff was compelled to file this complaint
engaging the services of counsel in the amount of Twenty
Thousand Pesos (P20,000.00).

WHEREFORE, premises considered, it is most respectfully prayed

unto this Honorable Court that, after hearing, judgment be rendered
ordering defendant:
 a. To deliver the subject jewelry;
b. To pay the plaintiff the cost of the suit.

General Santos City, Philippines, this 7th day of June, 2019.

PRINCESS ROSSHIEN L. HORTAL

Counsel For Petitioner
Zone 2, Blk. 5, Brgy. Fatima, General Santos City
IBP Lifetime No. 07083373; General Santos City
PTR No. 08073373; August 14, 2018, General Santos City
Roll of Attorney No. 454356
MCLE Compliance No. 1111111

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING

I, BEATRICE ALONDO, of legal age, Filipino citizen, single and

resident of 143 Iniwan St., Brgy. Naloko, General Santos City, after
having been duly sworn to in accordance with law do hereby depose
and say:
1. That I am the plaintiff in the above-entitled case;
 2. That I have caused the preparation of the foregoing
complaint and have read the allegations contained therein;

3. The allegations in the said complaint are true and

correct of my own knowledge and authentic records;

4. I hereby certify that I have not commenced any

other action or proceeding 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;

5. That if I should learn thereafter that a similar action

or proceeding has been filed or is pending, I hereby undertake
to report that fact within five (5) days therefrom to the court or
agency where the original pleading and sworn certification
contemplated herein have been filed;

6. I executed this verification/certification to attest to

the truth of the foregoing facts and to comply with the
provisions of Administrative Circular No. 04-94 of the Honorable
Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature

this 7th day of June 2019, in the City of General Santos.

BEATRICE ALONDO

SUBSCRIBED AND SWORN TO before me in the City of General

Santos on this 7th day of June 2019, affiant exhibiting before me her
identification:

Beatrice Alondo SSS No. 123456 Issued on February 6, 2011,

General Santos City
 PRINCESS ROSSHIEN L. HORTAL
Counsel For Plaintiff
Zone 2, Blk. 5, Brgy. Fatima, General Santos City
IBP Lifetime No. 07083373; General Santos City
PTR No. 08073373; August 14, 2018, General Santos City
Roll of Attorney No. 454356
MCLE Compliance No. 1111111

Doc. No. 2
Page No. 1
Book No. I
Series of 2019