Republic of the Philippines

5TH JUDICIAL REGION

Regional Trial Court
Branch 4
Legazpi City

RONNA M. NAZ, Civil Case No. 1524

Plaintiff FOR: COLLECTION OF
SUM OF MONEY WITH
DAMAGES
- versus -

SIONY M. CHUA,
Defendant x
-----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court, hereby
respectfully avers:

1. That plaintiff is of legal age, Filipino, married, and a resident of

Barangay East Washington, Legazpi City, Philippines while the defendant is also
of legal age, married, Filipino and a resident of Barangay Bitano, Legazpi City,
Philippines where summons and court processes may be served;

2. That on May 4, 2019, the defendant borrowed from the plaintiff a sum
of money amounting to Five Hundred Thousand Pesos(Php 500,000.00) with an
agreed interest of five percent (5%) per month as evidenced by a promissory note
herein attached as Annex “A” and form an integral part of this complaint;

3. The indebtedness of the defendant has become due and demandable

on May 4, 2020, as shown in the attached promissory note;

4. 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, as evidenced by Annex
“B” – Demand Letters;

5. 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 (PhP 500,000.00) plus interest
at the rate of five percent (5%) per month as stipulated in the promissory
note;

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

c. costs of this suit.

Other reliefs and remedies deemed just and equitable under the foregoing
premises are likewise prayed for.

Legazpi City, December 6, 2020.

Aaron M. Mangampo
ATTY. AARON M. MANGAMPO
Counsel for Petitioner
Mangampo Law Office, Rawis, Legazpi City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/20, Legazpi City
IBP NO. 123456, 01/04/14, Legazpi City
MCLE Comp. No. IV-0009876, 01/02/20
Email address: [email protected]
 REPUBLIC OF THE PHILIPPINES)
CITY OF LEGAZPI) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, RONNA M. NAZ, of legal age, Filipino, married, and a resident of

Barangay East Washington, Legazpi City, Philippines, after being sworn in
accordance with law, hereby depose and say:

(1) That I am the Plaintiff in the above-entitled case;

(2) That I have caused the preparation of the above Complaint and I have
read the same and understood the contents thereof;

(3) That the allegations contained therein are true and correct of my own
personal knowledge and based on authentic records.

(4) That I further certify that: I have not theretofore commenced any other
action or proceeding or filed any claim involving the same issues or matter in any
court, tribunal, or quasi-judicial agency and, to the best of my knowledge, no such
action or proceeding is pending therein; if I should thereafter learn that the same or
similar action or proceeding has been filed or is pending before the Supreme Court,
the Court of Appeals, or any other tribunal or quasi-judicial agency, I undertake to
report such fact within five (5) days therefrom to the court or agency wherein the
original pleading and sworn certification contemplated herein have been filed.

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

December 2020 at Legazpi City, Philippines.

R.M. Naz
RONNA M. NAZ
Affiant
PRC ID: 585487; Legazpi City
 SUBSCRIBED AND SWORN to before me, this 6th day of December
2020, affiant exhibiting to me his Professional Regulation Commission
Identification Card as shown above below his name as competent evidence of his
identity.

Aaron M. Mangampo
ATTY. AARON M. MANGAMPO
My Commission No. is 64
Expires on December 31, 2021
Mangampo Law Office, Rawis, Legazpi City
Roll of Attorneys No. 54321
PTR NO. 654321, 01/06/20, Legazpi City
IBP NO. 123456, 01/04/14, Legazpi City
MCLE Comp. No. IV-0009876, 01/02/20
Email address: [email protected]

Doc. No. 6;
Page No. 3;
Book No. 1;
Series of 2020;
Annex “A”
Annex “B”
 Republic of the Philippines
REGIONAL TRIAL COURT
Legazpi City
Fifth Judicial Region
Legazpi City

RONNA M. NAZ, Civil Case No. 1524

Plaintiff FOR: COLLECTION OF
SUM OF MONEY WITH
DAMAGES
- versus -

SIONY M. CHUA,
Defendant x
-----------------------x

JUDICIAL AFFIDAVIT OF
RONNA M. NAZ

I, Ronna M. Naz of legal age, married, and living at Barangay East Washington, Legazpi

City, petitioner in this case, state under oath as follows:

PRELIMINARY STATEMENT

The person examining me is Atty. Melvin Ramos with address at Bagumbayan, Legazpi

City. The examination is being held at the same address. I am answering her questions fully

conscious that I do so under oath and may face criminal liability for false testimony and perjury.

This affidavit/testimony of petitioner Ronna M. Naz is being offered to prove that the

respondent Siony M. Chua is indebted to plaintiff the sum of Five Hundred Thousand Pesos (Php

500,000.00), Philippine Currency. The petitioner’s testimony is also offered to prove that

defendant Siony M. Chua unlawfully refused to pay the lawful demand of the plaintiff.

1. Q. Please state your name and other personal circumstances for the record.

A. I am Ronna M. Naz, 30 years old, businesswoman, residing in Barangay East

Washington, Legazpi City

2. Q. Are you the same Ronna M. Naz, the petitioner in this case?

A. Yes sir.
3. Q. Do you know a certain Siony M. Chua?

A: Yes sir. She borrowed money from me in the sum of Php 500,000.00

4. Q: When did Siony borrow money from you?

A: May 4, 2019

5. Q: Do you have any proof that indeed Siony borrowed money from you on the said date?

A: Yes sir. She executed a promissory note where he had acknowledged his indebtedness and
where she had promised to pay me the sum of Php 500,000.00 on May 4, 2020. (Exhibit “A”)

6. Q: Did Siony pay his indebtedness on May 4, 2020?

A: She failed to pay the said obligation on due date,

7. Q: How did you settle this matter?

A: I sent two demand letters dated June 4, 2020 and August 4, 2020 but to no avail. I
approached Atty. Aaron Mangampo to formally send letter of demand payment of her
indebtedness. (Exhibit “B”)

8. Q: Did she answer your demand?

A: She failed to comply with such demand.

IN WITNESS WHEREOF, I have hereunto set my hand this 4th day of December 2020
at Legazpi City.

R.M. Naz

Ronna M. Naz

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and for Legazpi City
this 4th day of December 2020. Affiant personally came and appeared with Voter’s ID issued by
the COMELEC on July 13, 2020 at Legazpi City bearing his photograph and signature, known to
me as the same person who personally signed the foregoing instrument before me and avowed
under penalty of law to the whole truth of the contents of said instrument

Reina Moneda

Atty. REINA MONEDA

Notary Public
Doc. No. ____ Commission Serial No. 123456
Page No. ____ Notary Public for Legazpi City
Book No. ____ Until December 31, 2020
Series of 20__ Office: Bagumbayan, Legazpi City
Roll No. 34567
IBP Lifetime Roll No. 12345-56; 05/05/19 ;Legazpi
PTR No. 123457 04/13/19; Legazpi
MCLE Compliance Cert. No. 45678; 04/04/20
 I, Melvin Ramos, of legal age, Filipino, with postal address Bagumbayan, Legazpi City
after being duly sworn depose and say:

1. I was the one who conducted the examination of witness Ronna M. Naz at my
aforementioned office in Bagumbayan, Legazpi City;

2. I have faithfully recorded or caused to be recorded the questions I asked and the
corresponding answer that the witness gave;

3. I nor any other person then present or assisting her coached the witness regarding
her answers;

IN WITNESS WHEREOF, I have hereunto set my hand this 4th day of December 2020 at
Legazpi City.

Melvin Ramos

ATTY.MELVIN RAMOS
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in and for Legazpi City this 4th
day of December 2020. Affiant personally came and appeared with Voter’s ID issued by the
COMELEC on July 13, 2020 at Legazpi City bearing his photograph and signature, known to me
as the same person who personally signed the foregoing instrument before me and avowed
under penalty of law to the whole truth of the contents of said instrument.

Reina Moneda

Atty. REINA MONEDA

Notary Public
Doc. No. ____ Commission Serial No. 123456
Page No. ____ Notary Public for Legazpi City
Book No. ____ Until December 31, 2020
Series of 20__ Office: Bagumbayan, Legazpi City
Roll No. 34567
IBP Lifetime Roll No. 12345-56; 05/05/19 ;Legazpi
PTR No. 123457 04/13/19; Legazpi
MCLE Compliance Cert. No. 45678; 04/04/20
Exhibit “A”
Exhibit “B”