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    Complaint For Sum of Money

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    Luke
    Juan Dela Cruz is suing Pedro Santos for unpaid purchases made on credit totaling PHP 1,180,000 plus interest. Dela Cruz operates a poultry feed and supply business and extended credit to Santos for various purchases between October 2021 to March 2022. Despite demands for payment, Santos has failed to pay the outstanding amount which is now overdue. Dela Cruz is asking the court to order Santos to pay the principal amount owed plus 12% annual interest from the date of default and costs of the legal action.

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    Complaint For Sum of Money

    Uploaded by

    Luke
    48 views2 pages
    Juan Dela Cruz is suing Pedro Santos for unpaid purchases made on credit totaling PHP 1,180,000 plus interest. Dela Cruz operates a poultry feed and supply business and extended credit to Santos for various purchases between October 2021 to March 2022. Despite demands for payment, Santos has failed to pay the outstanding amount which is now overdue. Dela Cruz is asking the court to order Santos to pay the principal amount owed plus 12% annual interest from the date of default and costs of the legal action.

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    Complaint for Sum of Money

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    Juan Dela Cruz is suing Pedro Santos for unpaid purchases made on credit totaling PHP 1,180,000 plus interest. Dela Cruz operates a poultry feed and supply business and extended credit to Santos for various purchases between October 2021 to March 2022. Despite demands for payment, Santos has failed to pay the outstanding amount which is now overdue. Dela Cruz is asking the court to order Santos to pay the principal amount owed plus 12% annual interest from the date of default and costs of the legal action.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    48 views2 pages

    Complaint For Sum of Money

    Uploaded by

    Luke
    Juan Dela Cruz is suing Pedro Santos for unpaid purchases made on credit totaling PHP 1,180,000 plus interest. Dela Cruz operates a poultry feed and supply business and extended credit to Santos for various purchases between October 2021 to March 2022. Despite demands for payment, Santos has failed to pay the outstanding amount which is now overdue. Dela Cruz is asking the court to order Santos to pay the principal amount owed plus 12% annual interest from the date of default and costs of the legal action.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 2

    REPUBLIC OF THE PHILIPPINES

    REGIONAL TRIAL COURT OF BATANGAS


    JUDICIAL DISTRICT
    BRANCH ___

    JUAN DELA CRUZ,


    Plaintiff,
    Civil Case No. __________________
    - versus - For: Sum of Money

    PEDRO SANTOS,
    Defendant,
    x ------------------------------------- x

    COMPLAINT

    PLAINTIFF, through counsel, most respectfully states:

    1. That plaintiff is a Filipinio, of legal age, marreid and residing at C.


    Tirona St., Batangas City, whereas defendant is likewise a Filipino, of legal age,
    single and residing at 123, Alalum, San Pascual, Batangas, at which addresses the
    parties herein may be served with summons and other court processes;

    2. That plaintiff is a sole proprietor engaged in the sale of poultry feeds


    and supplies, doing business under the name Juan Poultry Supply, with business
    address at C. Tirona St., Batangas City. It sells poultry feeds and supplies on cash
    and on credit subject to a 5% interest to certain trusted clients. Purchases on
    account shall be payable within ten days from the date of the invoice.

    3. That on October 13, 2022, plaintiff reviewed the records of defendant,


    and it appeared that he made the following purchases on account:

    Date Sales Invoice Amount


    No.
    Oct. 2, 2021 12301 Php200,000.00
    Nov. 6, 2021 12311 Php100,000.00
    Dec. 5, 2021 12315 Php300,000.00
    Jan. 5, 2022 12325 Php150,000.00
    Feb. 9, 2022 12335 Php250,000.00

    1
    Mar. 3, 2022 12350 Php180,000.00
    Total (exclusive Php1,180,000.00
    of interest)

    4. That the records also revealed that defendant made no payment on


    the above purchases.

    5. On 13 October 2022, a demand letter was personally served and


    several personal demands were made by the credit collector of herein plaintiff but
    defendant failed to pay. It has been more than ten days since the receipt but
    defendant shows no intention of paying.

    6. That the defendant has failed and refused and still fails and refuses to
    pay the said indebtedness on due date, with the corresponding interest thereon to
    the herein plaintiff, despite repeated demands.

    WHEREFORE, it is most respectfully prayed for of this Honorable Court


    that after due hearing, judgement be rendered in favor of plaintiff and against the
    defendant in this manner:

    a. Ordering the defendant to pay plaintiff the amount of One Million, One
    Hundred Eighty Thousand Pesos (Php1,180,000.00), plus interest
    thereon at the rate of 12% per annum from October 2019, and until the
    same is fully paid; and
    b. Ordering the defendant to pay the costs of this suit.

    Plaintiff likewise prays for such other and further relief or reliefs as this
    Honorable Court may deem just and equitable in the premises.

    Batangas City, 18 November 2022

    BENJAMIN LUKE PHILLIP G. VERDADERO


    Roll of Attorneys No. 12345
    IBP No. 123456
    PTR No. 1234567 / January 03, 2023
    MCLE Compliance No. VII-1234567 / April 06, 2023
    Email address: lukeverdadero@gmail.com

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