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Complaint Affidavit of Mr. Jose Alamer

1. Jose Alamer is filing a complaint against Juan Dela Cruz for failing to repay a 100,000 peso loan that was due on August 29, 2020 as evidenced by a promissory note. 2. Despite repeated written and verbal demands as recently as September 28, 2020, Juan Dela Cruz has not paid back the loan. 3. Jose Alamer has been forced to file this legal action and hire a lawyer to recover the money owed, seeking to collect the full amount of the loan plus legal fees.

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Pau Perez
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166 views5 pages

Complaint Affidavit of Mr. Jose Alamer

1. Jose Alamer is filing a complaint against Juan Dela Cruz for failing to repay a 100,000 peso loan that was due on August 29, 2020 as evidenced by a promissory note. 2. Despite repeated written and verbal demands as recently as September 28, 2020, Juan Dela Cruz has not paid back the loan. 3. Jose Alamer has been forced to file this legal action and hire a lawyer to recover the money owed, seeking to collect the full amount of the loan plus legal fees.

Uploaded by

Pau Perez
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines )

Province of Malolos )S.S.


City of Bulacan )

C O M P L A I N T - A F F I D A V I T

I, JOSE ALAMER, Filipino, of legal age, married and a resident of Barangay


Pito-pito, Malolos, Bulacan after having been sworn to in accordance with law hereby
depose and say:

1. That I would like to file a complaint against JUAN DELA CRUZ of


Barangay Balogo, Sorsogon City for the collection of sum of money;

2. That on or about August 29, 2020, Mr. Juan Dela Cruz borrowed a
sum of money amounting to One Hundred Thousand Pesos (Php
100,000.00) from me payable within one month;

3. That, the indebtedness of Mr. Juan Dela Cruz has become due and
demandable, as evidenced by a promissory note herein attached as
“Annex A” and made part of this complaint;

4. That, despite of my repeated demands, both written and oral, he has


failed to fulfill his obligation as evidenced by “Annex B”;

5. That due to the unjust act of Mr. Juan Dela Cruz to comply with said
demands, I was compelled to institute this action engaging in the
services of counsel the amount of Php 1, 000.00;

6. That I attest to the veracity of the foregoing facts.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of October,


2020 at Malolos, Bulacan, Philippines.

JOSE ALAMER
Affiant
CERTIFICATION

I hereby certify that I personally examined the above-named affiant and that I am
satisfied that she has read and understood the contents herein and that the same are
true and correct to the best of her personal knowledge and belief.

VERIFICATION AND CERTIFICATION AGAINST NON-FORUM SHOPPING

I, JOSE ALAMER, of legal age, Filipino, married, and a resident of Barangay


Pito-pito, Bulacan, Metro Manila after having been sworn to in accordance with law
hereby depose and say:

1. That I am the complainant in the above-entitled case have caused this foregoing
complaint to be prepared; that I read and understood its contents which are true
and correct of my own personal knowledge and/or based on true records;

2. That I have not commenced any action or proceeding involving the same issue or
subject matter, and specifically the same check/s in the Supreme Court, the
Court of Appeals or any other tribunal or agency, that to the best of my
knowledge, no such action or proceeding is pending in the Supreme Court, the
Court of Appeals or any other tribunal or agency, and that, if I should learn
thereafter that a similar action or proceeding has been filed or is pending before
these courts or tribunal or agency, I undertake to report that fact to the Court
within five (5) days therefrom.

3. That the filing of this case is not in violation of the rule against splitting a single
cause of action or multiplicity of suits.

4. That I knowingly and voluntarily waive and forego the institution of any criminal
complaint for Violation of Batas Pambansa Blg. 22 against the defendant herein
based on the same check/s subject matter of this Small Claims Complaint.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day of October, 2020 at
Malolos, Bulacan, Philippines

JOSE ALAMER
Affiant
SUBSCRIBED AND SWORN TO before me, this 7th day of October, 2020.

ATTY. MARIA LOUISE GARCIA


My Commission No. is 83
Expires on March 25, 2025
Garcia Law Office, Malolos, Bulacan
Roll of Attorneys No. 35123
PTR No. 821074, 04/15/2019, Bulacan
IBP No. 410321, 04/13/2019, Bulacan
MCLE Comp. No. III – 0008673, 04/ 11/ 2019

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2020;
Annex A

PROMISSORY NOTE

Php 100,000.00

August 29, 2020

FOR VALUE RECEIVED, I promise to pay without need of demand to the order of MR.
JUAN DELA CRUZ, the sum of ONE HUNDRED THOUSAND PESOS (Php 100,00.00)
Philippine Currency, payable in ONE month.
Annex B

Mr. Jose Alamer


Brgy. Pito pito, Bulacan, NCR

Mr. Juan Dela Cruz

September 28, 2020

Dear Mr. Juan Dela Cruz,

As of the above date, you still owe Php 100, 000.00 and you promised to pay it within a month. Your
payment is past due by 30 days.

If you have any questions, please contact me via contact information listed below. If you do not provide
payment within 7 days of receiving this letter, we may pursue further legal action.

Best regards,

Mr. Jose Alamer


Brgy. Pito pito, Bulacan, NCR

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


8. defendant failed, neglected and refused to fulfill obligations without just
and
9. valid grounds to the continued damage and prejudice of plaintiff, as
10. evidenced by Annex
11. That despite plaintiff's repeated demands, both written and verbal,
12. defendant failed, neglected and refused to fulfill obligations without just
and
13. valid grounds to the continued damage and prejudice of plaintiff, as
14. evidenced by An

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