Arnel A. Diestro,: Plaintiff

Republic of the Philippines
NATIONAL CAPITAL JUDICIAL REGION

Regional Trial Court
Branch 66
Makati City
ARNEL A. DIESTRO, Civil Case No. 12456

Plaintiff FOR: COLLECTION FOR A
SUM OF MONEY WITH
DAMAGES
- versus -
CELESTE PALIA,
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 25

Cembo Street, Makati City, Philippines while the defendant is also of legal
age, married, Filipino and a resident of Unit 245 Torre Lorenzo, Manila City,
Philippines where summons and court processes may be served;
2. That on February 28, 2018, the defendant borrowed from the

plaintiff a sum of money amounting to One Million Pesos
(PhP1,000,000.00) with an agreed interest of five percent (3%) per month as
evidenced by a promissory note herein attached as Annex “A” and form an
integral part of this complaint;
3. That as shown in the attached promissory note, the indebtedness of

the defendant has become due and demandable on February 28, 2019;
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 in order to enforce his rights and interests, has
sought the services of a legal counsel with attorney’s fees amounting to One
Hundred Thousand Pesos (PhP 200,000.00) and an appearance fee of Two
Thousand Pesos (PhP 3,000.00) per hearing as evidenced by Annex “C” –
Contract for Legal Services;
6. That the plaintiff has paid for litigation expenses amounting to
Twenty Thousand Pesos (PhP 30,000.00) as evidenced by Annex “D” –
Official Receipt;
7. 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 One Million Pesos (PhP 1,000,000.00) plus interest at

the rate of five percent (3%) per month 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

200,000.00) and an appearance fee of Two Thousand Pesos (PhP
3,000.00) per hearing
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.
Iloilo City, December 6, 2014.
ATTY. AIHRA NICOLE V. DIESTRO

Counsel for Petitioner
Diestro Law Office, Alta Homes, Las Piñas City
Roll of Attorneys No. 45789
PTR NO. 123456, 01/06/17, Las Piñas City
IBP NO. 723614, 01/04/17, Las Piñas City
MCLE Comp. No. IV-0009876, 01/02/20
REPUBLIC OF THE PHILIPPINES)
CITY OF MAKATI) SS.
x----------------------------x
VERIFICATION AND CERTIFICATION
I, ARNEL A. DIESTRO, of legal age, Filipino, married, and a

resident of Alta Tierra Village, Jaro, Iloilo 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 August 2019 at Makati City, Philippines.
ARNEL A. DIESTRO
Affiant
TIN 90926-025; Makati City
SUBSCRIBED AND SWORN to before me, this 6th day of
December 2014, affiant exhibiting to me his Tax Identification Card as
shown above below his name as competent evidence of his identity.
ATTY. AIHRA NICOLE V. DIESTRO

My Commission No. is 22
Expires on December 31, 2020
Diestro Law Office, Alta Homes, Las Piñas City
Roll of Attorneys No. 45789
PTR NO. 123456, 01/06/17, Las Piñas City
IBP NO. 723614, 01/04/17, Las Piñas City
MCLE Comp. No. IV-0009876, 01/02/20
Doc. No. 365;

Page No. 2;
Book No. 1;
Series of 2019;

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Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

ARNEL A. DIESTRO, Civil Case No. 12456

Plaintiff, through the undersigned counsel unto this Honorable Court,

1. That plaintiff is of legal age, Filipino, married, and a resident of 25

2. That on February 28, 2018, the defendant borrowed from the

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

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

WHEREFORE, premises considered, it is hereby respectfully prayed

a. the sum of One Million Pesos (PhP 1,000,000.00) plus interest at

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

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

d. litigation expenses amounting to Twenty Thousand Pesos (PhP

Iloilo City, December 6, 2014.

ATTY. AIHRA NICOLE V. DIESTRO

VERIFICATION AND CERTIFICATION

I, ARNEL A. DIESTRO, of legal age, Filipino, married, and a

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

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

ATTY. AIHRA NICOLE V. DIESTRO

Doc. No. 365;

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