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    Complaint Fred

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    Red Bilyonaryo Masgwapothanyou
    Felicisimo Colas Jr. filed a complaint against BCFA Construction Company Inc. and its president Arnel Alvarado for breach of contract and recovery of damages. Colas alleges that he entered into a verbal contract with BCFA to provide plumbing and electrical design and drafting services for its employee housing project for a fee of PHP 1.5 million. Colas fulfilled his obligations by submitting the required designs and plans on March 12, 2018. However, BCFA failed and refused to pay Colas the agreed fee despite demand, causing Colas to suffer actual damages of PHP 497,964.66. Colas is seeking payment of PHP 1.5 million in actual damages, PHP 200,000 in exemplary damages

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    Complaint Fred

    Uploaded by

    Red Bilyonaryo Masgwapothanyou
    60 views7 pages
    Felicisimo Colas Jr. filed a complaint against BCFA Construction Company Inc. and its president Arnel Alvarado for breach of contract and recovery of damages. Colas alleges that he entered into a verbal contract with BCFA to provide plumbing and electrical design and drafting services for its employee housing project for a fee of PHP 1.5 million. Colas fulfilled his obligations by submitting the required designs and plans on March 12, 2018. However, BCFA failed and refused to pay Colas the agreed fee despite demand, causing Colas to suffer actual damages of PHP 497,964.66. Colas is seeking payment of PHP 1.5 million in actual damages, PHP 200,000 in exemplary damages

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    Felicisimo Colas Jr. filed a complaint against BCFA Construction Company Inc. and its president Arnel Alvarado for breach of contract and recovery of damages. Colas alleges that he entered into a verbal contract with BCFA to provide plumbing and electrical design and drafting services for its employee housing project for a fee of PHP 1.5 million. Colas fulfilled his obligations by submitting the required designs and plans on March 12, 2018. However, BCFA failed and refused to pay Colas the agreed fee despite demand, causing Colas to suffer actual damages of PHP 497,964.66. Colas is seeking payment of PHP 1.5 million in actual damages, PHP 200,000 in exemplary damages

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    60 views7 pages

    Complaint Fred

    Uploaded by

    Red Bilyonaryo Masgwapothanyou
    Felicisimo Colas Jr. filed a complaint against BCFA Construction Company Inc. and its president Arnel Alvarado for breach of contract and recovery of damages. Colas alleges that he entered into a verbal contract with BCFA to provide plumbing and electrical design and drafting services for its employee housing project for a fee of PHP 1.5 million. Colas fulfilled his obligations by submitting the required designs and plans on March 12, 2018. However, BCFA failed and refused to pay Colas the agreed fee despite demand, causing Colas to suffer actual damages of PHP 497,964.66. Colas is seeking payment of PHP 1.5 million in actual damages, PHP 200,000 in exemplary damages

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    © All Rights Reserved
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    Republic of the Philippines

    MUNICIPAL TRIAL COURT


    PASAY, BRANCH 12
    _______________
    Felicisimo R. Colas, Jr.
    Plaintiff,
    - versus - CIIL CAS! NO. 2"1#PSY
    For$ Breac% o& Co'(rac( a')
    Reco*er+ o& ,ama-es
    BCFA Co's(r.c(io' Com/a'+, I'c.,
    Ar'el Al*ara)o, Presi)e'(
    Defendant.
    x------------------------------------------------x
    COMPLAINT
    COMES NOW Plaintiff, by an thru the unersi!ne counsel, unto
    this "onorable Court, #ost respectfully states that$
    %&' Plaintiff is of le!al a!e, sin!le an resiin! at No( )* Na!oya
    Street, +, "o#es -as Pinas City( .t #ay be serve /ith court
    processes at the unersi!ne counsel0s aress(
    1
    %1' 2efenant is a corporation uly or!ani3e an existin! uner
    an by virtue of the la/s of the Republic of the Philippines /ith
    principal office aress at Suite )*4, ), Colu#bian +uilin!,
    No( &4* West 5venue, +r!y( Phil-a#,6ue3on City, /here
    su##ons an a copy of the co#plaint as /ell as other court
    processes #ay be serve(
    .n connection /ith its business concerns, efenant corporation
    throu!h its presient 5rnel 5lvarao verbally contracte
    plaintiff, /ho is a license civil en!ineer, for the latter to
    provie the plu#bin! an electrical esi!n an raftin!
    re7uire#ents for its propose 2+M E#ployees "ousin! Pro8ect
    locate at Malacanan! !rouns, Cristobal Street, 9N 5venue,
    Manila, for a total contract price of P &,:**,***(**( ;he
    contract price represente plaintiff<s professional fees for his
    services(
    %=' So#eti#e on 1> March 1*&), in a strict co#pliance of their
    a!ree#ent, plaintiff sub#itte to efenant corporation all the
    plu#bin! an electrical plans pertainin! to the 2+M pro8ect,
    /hich efenant corporation accepte to its full satisfaction an
    /ithout any reservation(
    %)' 5s provie in sai a!ree#ent, efenant corporation /as to
    pay plaintiff the a#ount of P&,:**,***(** upon plaintiff<s
    2
    sub#ission an efenant<s acceptance of the re7uire electrical
    an plu#bin! esi!n an raftin! re7uire#ents(
    %:' Plaintiff has fulfille his part of the a!ree#ent an in !oo faith
    perfor#e his obli!ations to co#e up /ith the plu#bin!
    esi!ns an electrical plans uly custo#i3e for the 2+M
    "ousin! pro8ect( Plaintiff has to hire services of an architect
    an electrical en!ineer, such professional services has been
    avance by the plaintiff( Plaintiff then, incurre the expenses
    a#ountin! Four Hundred Ninety-seven Thousand Nine
    Hundred Sixty-four Pesos and 66/100 %P)?>,?4)(44'( 5ttache
    an #ar@e as 5nnex A5B is the brea@o/n of service expenses
    an #ae an inte!ral part of this co#plaint(
    %4' Plaintiff, thru counsel, e#ane fro# the efenant in /ritin!
    the a!ree contract price in the a#ount of ne !illion Five
    Hundred Pesos, Phili""ine #urren$y %P&,:**,***(**'( 5 copy
    of the sa#e e#an letter /ith the corresponin! re!istry
    receipt an return car are attache to for# inte!ral parts of the
    co#plaint an respectively #ar@e as 5nnex A+,B series(
    3
    %>' 2espite e#an, efenant faile anCor refuse to rei#burse
    the plaintiff for the afore#entione a#ount of expenses(
    %D' +y reason of efenant0s contu#acious refusal to co#ply /ith
    his 8ust an vali obli!ation an /anton breach of obli!ation,
    suffere actual a#a!es in the a#ount of Four Hundred
    Ninety-seven Thousand Nine Hundred Sixty-four Pesos and
    66/100 Phili""ine #urren$y %P)?>,?4)(44'(
    %?' 2efenant contracte the a!ree#ent /ith the plaintiff in ba
    faith an every intention to efrau the latter causin! /illful
    in8ury upon plaintiff( +y enterin! into the a!ree#ent /ith
    #alicious intention, efenant faile to act /ith 8ustice, honesty
    an !oo faith an !ive plaintiff its ue(
    %&*' ;o serve as an exa#ple for public !oo an to avoi si#ilar
    incients, efenant shoul be orere to pay plaintiff
    exe#plary a#a!es in the a#ount of PESOS ;WEN;E-
    ;"O9S5N2 %P1*,***(**' sub8ect to the iscretion of the
    "onorable Court(
    %&&' 2ue to the efenant0s un8ust failure anCor refusal to rei#burse
    plaintiff, the latter is constraine to sue in court an incur
    4
    aitional expenses in the concept of attorney0s fees an
    liti!ation expenses in the a#ount of PESOS ;WEN;E
    ;"O9S5N2 %P1*,***(**'(
    W"ERE,ORE, it is #ost respectfully praye of this "onorable Court that
    8u!#ent be renere orerin! the efenant to pay the plaintiff the
    follo/in!$
    ;he a#ount ne !illion Five Hundred Pesos Phili""ine #urren$y
    %P&,:**,***(**' as actual a#a!esF
    ;he a#ount of PESOS ;WEN;E ;"O9S5N2 %P1*,***' for exe#plary
    a#a!esF
    ;he a#ount of PESOS ;WEN;E ;"O9S5N2 %P1*,***(**' for an as
    attorney0s feesF
    ;he cost of the suitF
    Such other reliefs an re#eies, 8ust an e7uitable uner the pre#ises, are
    li@e/ise praye for(
    Pasay City, 1& Septe#ber 1*&)(
    JA!MY ILLANU!A
    Counsel for Plaintiff
    ?, +ala!tas Royale Mansions
    "u#ilia Street, Pasay City
    5ttorney0s Roll No( &1=):
    .+P No( )=>)>&C*&-*:-?D
    P;R No( 41:>*=C*&-*>-*DC Pasay
    5
    C!RTIFICATION AN, !RIFICATION
    ., ,elicisi#o R( Colas Gr(,, of le!al a!e, /io/, ,ilipino an a resient
    of No( )* Na!oya Street, +( ,( "o#es, -as PiHas City, avers uner oath that$
    &' . a# the plaintiff in the above entitle caseF . cause the preparation
    of the fore!oin! co#plaintF an all #aterial alle!ations therein are true of
    #y o/n @no/le!eF
    1' . have not co##ence any action or file any clai# involvin! the
    sa#e issues in any court, tribunal or 7uasi-8uicial a!ency an to the best of
    #y @no/le!e, no such other action or clai# is penin! thereinF
    =' Shoul . hereafter learn that the sa#e or si#ilar action or clai# has
    been file or is penin! before any court, tribunal or 7uasi-8uicial a!ency, .
    unerta@e to report sai fact /ithin five %:' ays fro# such @no/le!e to
    this "onorable Court(
    ,E-.C.S.MO R( CO-5S GR(,
    5ffiant
    6
    REP9+-.C O, ;"E P".-.PP.NES '
    _______, City ' S(S(
    S9+SCR.+E2 5N2 SWORN to before #e this __ ay of Septe#ber,
    1*&) affiant exhibitin! to #e her SSS .(2( No ____________, issue on
    _________ , at _______ City(
    NOTARY PUBLIC
    2oc No( 0000000
    Pa!e No( 0000000
    +oo@ No( 0000000
    Series of 1*&)
    7

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