Complaint For Collection of Sum of Money

Republic of the Philippines
Third Judicial Region

MUNICIPAL TRIAL COURT IN THE CITIES
Branch 1, Cabanatuan City
Peter Sicat,
Plaintiff,
-versus-
Civil Case No. 12693

For: Collection of Sum of Money
Arnel Romero,
Defendant.
x- - - - - - - - - - - - - - - - - x
COMPLAINT
Plaintiff, by counsel respectfully states:
1.
That the plaintiff is a Filipino, of legal age, and a resident of Block

2 Lot 4 De Guzman Subdivision, Bantug Norte, Cabanatuan City.
2.
That the defendant is Filipino, of legal age, and a resident of 354

Del Pilar Extension, Sumacab East, Cabanatuan City, where he
may be served with summons and other court processes;
3.
That on October 6, 2016, plaintiff together with the defendant went

to Shiro KTV Bar, in Bantug Norte, Cabanatuan City to have some
Rest and Relaxation. The bill representing the VIP charges, ladies
drinks and the professional fee of the bar hostess Lady Arwina
amounted to a total of Two Hundred Thousand and One Pesos
(P200,001.00);
4.
That the defendant offered to pay for the bill and shortly thereafter
executed a deed of donation of an Equitable PCI Bank check with
check No. 0012324 post-dated on October 13, 2016 in the amount
of Two Hundred Thousand and One Pesos (P200,001.00) and
issued the same to the plaintiff, and that the plaintiff in accepting
the donation signed the deed of acceptance incorporated in said
deed of donation. A copy of the deed of donation and acceptance
is herewith attached as Annex A;
5.
That because of said donation, plaintiff agreed to pay the bill due
in behalf of the defendant and through his credit card which was
duly charged by Shiro KTV Bar. A photocopy of the machine-
generated charge slip reflecting the bill and the billing statement
containing said charge are herewith attached as Annex B and
Annex B-1, respectively;
6.
That when the check fell due on October 13, 2016, plaintiff
presented the check for payment in Equitable PCI Bank Talavera
Branch but the same was dishonored for being drawn against a
CLOSED ACCOUNT. The photocopy of the check stamped with
closed account as Annex C.
7.
That on October 14, 2016, plaintiff called the defendants attention

regarding the said dishonor of the check;
8.
That despite demands made orally and in writing personally

received by the defendant (Notice of Dishonor and Demand for
Payment attached as Annex D and Final Demand for Payment as
Annex E both signed as received) from the plaintiff, the former
failed and refused to pay or make good the amount of said check;
9.
That due to the unjust refusal of defendant to comply with the

demands, plaintiff was compelled to file the instant action
engaging the services of a counsel in the amount of P20,000.00.
WHEREFORE, it is respectfully prayed that judgment be rendered

against the defendant to pay the plaintiff the sum of Two Hundred Thousand
and One Pesos (P200,001.00) plus legal interest from the date of the
instrument until full amount is paid and attorneys fees in the amount of
P20,000.00 and costs of suit.
Other just and equitable reliefs are likewise prayed for.
Cabanatuan City, November 16, 2016.
Atty. Venus Leilani V. Granado
Counsel for the Plaintiff
nd
2 Floor, Francisco Building,
Zulueta Street, Cabanatuan City
Attorneys Roll No. 987789
IBP O.R. No. 51328-01/15/16-Cabanatuan City
PTR O.R. No. 32145-01/05/16-Cabanatuan City
MCLE Compliance No. II-0006542-Nov. 15, 2014
VERIFICATION AND CERTIFICATION OF NON-FORUM
SHOPPING
I, Peter Sicat, of legal age, after having been duly sworn, depose and state
that:
I am the Plaintiff in the foregoing Complaint for Sum of Money.
I caused the preparation of the Complaint, which I Have fully read and
understood.
I hereby affirm that all factual allegations contained in said Complaint are
tru and correct of my own personal knowledge and belief, as well as true and
correct on the basis of authentic documents and records in my possession.
I certify that I have not heretofore commenced any action or filed any claim
involving the same issues in any court, tribunal, or quasi-judicial agency.
If I should hereafter learn that any other similar action or claim has been
filed or is pending, I shall report that fact within five (five) days from
knowledge thereof to this Honorable Court.
PETER SICAT
SUBSCRIBED AND SWORN to before me this 16th day of

November, 2016 in the City of Cabanatuan, affiant exhibiting to me his
Passport No. XX6534571 issued at the City of Manila on May 2, 2014.
VENUS LEILANI V. GRANADO

Notary Public for the City of Cabanatuan
2nd Floor, Francisco Building,
Zulueta Street, Cabanatuan City
Commission until December 31, 2016
Attorneys Roll No. 987789
IBP O.R. No. 51328-01/15/16-Cabanatuan
City
PTR O.R. No. 32145-01/05/16-Cabanatuan
City
MCLE Compliance No. II-0006542-Nov. 15,
2014
Doc. No. 576
Page No. 86
Book No. XXI
Series of 2016.

Complaint For Collection of Sum of Money

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Republic of the Philippines

Third Judicial Region

Civil Case No. 12693

That the plaintiff is a Filipino, of legal age, and a resident of Block

That the defendant is Filipino, of legal age, and a resident of 354

That on October 6, 2016, plaintiff together with the defendant went

That on October 14, 2016, plaintiff called the defendants attention

That despite demands made orally and in writing personally

That due to the unjust refusal of defendant to comply with the

WHEREFORE, it is respectfully prayed that judgment be rendered

SUBSCRIBED AND SWORN to before me this 16th day of

VENUS LEILANI V. GRANADO

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