Bacsal
Bacsal
Bacsal
C O M P LA I N T
domestic corporation duly organized and existing under the laws of the Republic of the
Philippines, with principal office addressed at No. 162 L.P. Leviste St., Salcedo Village,
Blk. 5, Lot 42 Urban Bliss, Barangka (UBB), Barangka, Marikina City where she may be
3. Defendant Susan Lozada is a Filipino, of legal age and with residence at Blk.
6, Lot 18 Urban Bliss, Barangka (UBB), Barangka, Marikina City where she may be
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4. Defendant Violeta Padilla is a Filipino, of legal age and with residence at Blk.
5, Lot 35 Urban Bliss Barangka (UBB), Barangka, Marikina City, where she may be
residence at Blk. 5, Lot 43 Urban Bliss Barangka (UBB), Barangka Marikina City, where
residence at Blk. 6, Lot 31 Urban Bliss Barangka (UBB), Barangka Marikina City, where
CAUSE OF ACTION
Kaunlaran (“PASAKA” for brevity) loan from Anchor in the amount of PESOS:
FIFTEEN THOUSAND (P15,000.00) with twenty four percent (24%) interest rate per
annum, as evidenced by Promissory Note dated 3 November 2004 duly executed and
signed by defendants. A copy of said promissory note is hereto attached as Annex “A”
promissory note. It is stated in the promissory note that failure to pay any installment as
and when the same becomes due shall render the whole sum then remaining unpaid as
well as the stipulated interest and penalty charges, immediately due and payable.
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10. Due to such default, Anchor demanded from herein defendants the
settlement of their loan obligation but despite such oral and written demands for the
payment of the outstanding balance, defendants failed to settle their obligation. Copy of
the demand letter dated 29 November 2005 and its corresponding Registry Return Cards
11. As of May 26, 2006, the outstanding balance of the defendants exclusive
“H”.
their failure to pay their monthly obligations to the plaintiff, are liable to pay penalty
charges of FIVE PERCENT (5%) per month or a fraction thereof which shall be added
13. As stipulated in the same promissory note, defendants are likewise liable
of the total sum due and another TWENTY FIVE PERCENT (25%) of the total sum
due as attorney’s fees since the court action is resorted to for the collection of defendant’s
obligation.
PRAY E R
Court that after trial on merits, judgment be rendered ordering herein defendants to pay
FORTY FOUR (P6,344.00) exclusive of interest and penalty charges which have
accrued and will continuously accrue from May 26, 2006 until fully paid and a penalty of
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FIVE PERCENT (5%) per month or a fraction thereof on all unpaid monthly
Other relief just and equitable in the premises are likewise prayed for.
REYNALDO M. DE SAGUN
IBP No. 663894 / 12-28-05 / PPLM
PTR No. 4186600 / 01-05-06 / Makati City
Roll No. 45924
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162 Champaca II Building
L.P. Leviste Street, Salcedo Village
Makati City
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3. I caused the preparation of the foregoing Complaint and attest that I read
and understood the same and all the allegations therein are true and correct to the best of
my personal knowledge and bank records;
FREEDOM C. DE JESUS
Affi ant
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