Write a Counter Affidavit for Collection of Sum of Money

Republic of the Philippines

4TH JUDICIAL REGION

Regional Trial Court Branch 123,

Bacoor City

AAAA B. CCC, Civil Case No. 54321

Plaintiff FOR: COLLECTION FOR A SUM OF MONEY WITH DAMAGES

- versus -

DDD E. FFF,

Defendant

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COMPLAINT

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

1. That plaintiffis of legalage, Filipino, married,and a residentof Lancaster Subdivision, Mambog ,Bacoor City, Philippines while the defendant isalso of legalage, married, Filipinoand a residentof Brgy. Anabu , Imus City, Philippines where summons and court processes may be served;

2. That on July 29, 2019, 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 (5%) per month as evidenced by a promissory noteherein attached asAnnex "A" andform an integralpart of this complaint;

3. That as shown in the attached promissory note, the indebtedness of the defendant has become due and demandable on July 29, 2021;

4. That despite plaintiff's repeated demands, both written and verbal, defendant failed, neglected and refused to fulfill obligations without just and validgrounds to thecontinued damage andprejudice of plaintiff,as evidenced by Annex "B" - Demand Letters;

5. That the plaintiff in order to enforce his rights and interests, has sought the servicesof a legalcounsel with attorney'sfees amounting to FiftyThousand Pesos (PhP50,000.00) and anappearance fee of Ten Thousand Pesos (PhP 10,000.00) 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 20,000.00) 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 rateof five percent(5%) per monthas stipulated in the promissory note;

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

c.attorney's fees amounting to Fifty Thousand Pesos (PhP50,000.00) and an appearance fee of Ten Thousand Pesos (PhP10,000.00) per hearing

d. litigation expenses amounting to Twenty Thousand Pesos (PhP20,000.00).

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

Bacoor City, March 30,2022.

ATTY. XXXX Y. ZZZZZ

Counsel for Petitioner

ZZZZ Unit 1, 678 Center, Bacoor City

Roll of Attorneys No. 12345

PTR NO. 654321, 01/06/22, Bacoor City IBP NO. 123456, 01/04/22 Bacoor City MCLE Comp. No. IV-0009876, 01/02/22