4-Complaint For Sum of Money

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Republic of the Philippines

REGIONAL TRIAL COURT


Ninth Judicial District
Branch 14
Zamboanga City

ROBB M. SANDOVAL,
Plaintiff, CIVIL CASE NO: 13335
For: COMPLAINT FOR SUM OF
MONEY
-versus-

SANDOR B. CARBONELL,
Defendant.
x-----------------x

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:


1. Plaintiff Robb M. Sandoval is a Filipino citizen, of legal age,
married and residing at Banilad, Zamboanga City where he may be served
with court processes, motions, and decision;

2. Defendant Sandor B. Carbonell is a Filipino citizen, of legal age,


and residing Talamban, Zamboanga City where he may be served with
summons and other court processes;

3. That on April 1, 2020, defendant executed a promissory note in


favor of the plaintiff in the amount of FIVE HUNDRED THOUSAND
PESOS (P500, 000.00) payable within 30 days from the date of the
promissory note (attached as ³Annex A´) which reads as follows:
Zamboanga City, Philippines
1 April 2020

I promise to pay Robb M. Sandoval the sum of FIVE HUNDRED


THOUSAND PESOS (P500,000.00) or order within 30 days from this date.

Sandor B. Carbonell

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4. That the 30-day period had elapsed and despite demands made
orally and in writing (attached as ³Annex B´) by the plaintiff, defendant
refused and failed to pay the amount stated in the promissory note;

5. 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 counsel in the amount of P10,000.00.

PRAYER
WHEREFORE, plaintiff respectfully prays for judgment in his favor
through a Decision directing defendant to pay him FIVE HUNDRED
THOUSAND PESOS (P500, 000.00), with legal interest, as ACTUAL
DAMAGES and TEN THOUSAND PESOS (P10, 000.00) as Attorney’s
Fees.
Plaintiff prays for such other and further reliefs as may be just and
equitable reliefs
Zamboanga City, May 6, 2020

ATTY. KHALIL A. LA JARDIN


Counsel for the Plaintiff
Until December 21, 2020
PTR No. 54321; Zamboanga City; 1/3/2020
Roll of Atty. No. 54321
IBP No. 68765
Bird’s Lair, Zamboanga City

REPUBLIC OF THE PHILIPPINES )


CITY OF ZAMBOANGA ) S.S.

VERIFICATION AND CERTIFICATION

I, ROBB M. SANDOVAL, Filipino, of legal age, after been duly


sworn, depose and state that:
1. I am the Plaintiff in the above-entitled case;

2. The facts stated in the above complaint are true and correct to
the best of my knowledge and authentic records;

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3. I have not commenced any action or filed any claim 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 in them; and

4. If I should learn that the same or similar action or claim has


been filed or is pending after its filing, I shall report that fact within
five (5) days from notice to the court or where the complaint or
initiatory pleading has been filed.

WITNESS WHEREOF, I hereunto set my hand this 6th day of May,


2020 at Zamboanga City, Philippines.

ROBB M. SANDOVAL
Plaintiff

SUBSCRIBED AND SWORN TO before me this 6th day of May at


Zamboanga City, affiant having exhibited to me her CTCNo.133143364
issued on January 22, 2015 at Zamboanga City.

Doc. No. xx;


Page No.xx;
Book No. xx;
Series of 2020.

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