Regional Trial Court National Capital Judicial Region Quezon City Branch 31

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Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION

QUEZON CITY

BRANCH 31

NICOLE DOMINIQUE N. IBAY,

Plaintiff,

vs CIVIL CASE NO. 6171995

Collection of Sum of Money

SELENA GOMEZ,

Defendant.

x--------------------------------------------x

COMPLAINT

PLAINTIFF NICOLE DOMINIQUE N. IBAY, by counsel, to this

Honorable Court, respectfully states that:

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1. Plaintiff, Nicole Dominique N. Ibay, 24 years old, Filipino, single,

residing at #78 B Gen. Segundo St. heroes Hill, Quezon City

2. Defendant, Selena Gomez, 24 years old, Filipino, single, residing at

tower 3 Unit b The good place, Quezon City, where they may be served

with summons and other processes of this Honorable Court;

3. That on October 1, 2016 defendant borrowed from the plaintiff a sum

of money amounting to Five Hundred Thousand Pesos

(PhP500,000.00) with an agreed interest of twelve percent (12%) per

annum as evidenced by a promissory note dated October 15, 2016

herein attached as Annex “A” and form an integral part of this

complaint;

4. That as shown in the attached promissory note, the indebtedness of

the defendant has become due and demandable on October 15, 2017;

5. That plaintiff writes a demand letter giving fifteen (15) days for

defendant to comply with his obligation. Demand letter herein attached

as Annex “B” and form an integral part of this complaint;

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

defendant failed, neglected and refused to fulfill obligations without just

and valid grounds to the continued damage and prejudice of plaintiff;

7. That the plaintiff in order to enforce his rights and interests, has

sought the services of a legal counsel with attorney’s fees amounting

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to One Hundred Thousand Pesos (Php 100,000.00) and an

appearance fee of Two Thousand Pesos (PhP 2,000.00) per hearing

as evidenced by Annex “C” – Contract for Legal Services;

8. That the plaintiff has paid for litigation expenses amounting to

Twenty Thousand Pesos (PhP 20,000.00) as evidenced by Annex “D”

– Official Receipt;

9. That the plaintiff has suffered moral damages at the sum discretion

of the Honorable Court;

WHEREFORE, premises considered, it is hereby 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 Five Hundred Thousand Pesos (P 500,000.00)

plus interest at the rate of twelve percent (12%) per annual as

stipulated in the promissory note;

b. moral damages, exemplary damages at the sum discretion of

the court;

c. attorney’s fees amounting to One Hundred Thousand Pesos

(PhP 100,000.00) and an appearance fee of Two Thousand

Pesos (PhP 2,000.00) per hearing;

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d. litigation expenses amounting to Twenty Thousand Pesos

(PhP 20,000.00).

Other reliefs and remedies deemed just and equitable under the

foregoing premises are likewise prayed for.

Quezon City, November 7, 2019

ATTY. HARRY EDWARD STYLES

Counsel for Petitioner

Styles-Malik Law Office – Quezon City

Roll of Attorneys No. 54321

PTR NO. 654321, 01/06/17, Quezon City

IBP NO. 123456, 01/04/17, Quezon City

MCLE Comp. No. IV-0009876, 12/31/19

VERIFICATION/CERTIFICATION

I, Nicole Dominique N. Ibay, 24 years old, Filipino, single and

resident of #78B Gen. Segundo St, Heroes Hill, Quezon City, after

having been sworn in accordance with law, hereby depose and state:

1. That I am the complainant in the above-entitled case;

2. That I have caused the preparation of the foregoing Complaint;

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3. That I have read and understood all the allegations contained

therein, and the same is true and correct of my own personal

knowledge and based on authentic records;

4. That I certify under oath that I have not commenced any other

action or proceeding which is pending in the Supreme Court, the Court

of Appeals, or any other tribunal or agency. To the best of my

knowledge, no such action or proceeding is pending in the Supreme

Court, the Court of Appeals, or any other tribunal or agency;

5. I likewise undertake that if there is any such action or proceeding

which is either pending or may have been terminated, I will state the

status thereof. If I should thereafter learn that the similar action or

proceedings has been filed or is pending before the Supreme Court,

the Court of Appeals, or any other tribunal or agency. I will undertake

to report the fact within five days therefrom to the Court or agency

wherein the original pleadings an sworn certification contemplated in

Administrative Circular No. 04-94 February 8, 1994.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

11th day of November 2019, in Quezon City, Philippines.

Affiant

Driver’s License No. AO1-98-065487

Expiry Date: 2020-01-17

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SSS ID No. 33-44556677

SUBSCRIBED AND SWORN TO BEFORE ME, a Notary Public

for and in Quezon City, affiant personally appeared having exhibited to

me her Social Security System Identification Card which details are

indicated below her name and signature.

WITNESS MY HAND AND SEAL this 11th day of November 2019

in Quezon City.

ATTY. LIAM PAYNE

NOTARY PUBLIC

Roll of Attorneys No. 543213

PTR NO. 12345, 04/06/17, Quezon City

IBP NO. 23456, 04/04/17, Quezon City

MCLE Comp. No. IV-0009435, 31/12/19

Doc. No. _____;

Page No. _____;

Book No. _____;

Series of 2019

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