Write counter complaint for the said complaint on sum of money in legal form

Republic of the Philippines

4 TH 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

AAAAB.CCC

- versus -

DDD E. FFF, 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 Lancaster Subdivision, Mambog ,Bacoor City, Philippines while the defendant is also of legal age, married, Filipino and a resident of 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 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 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 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 Fifty Thousand Pesos (PhP 50,000.00) and an appearance 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 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. attorney's fees amounting to Fifty Thousand Pesos (PhP 50,000.00) and an appearance fee of Ten Thousand Pesos (PhP 10,000.00) 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.

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