Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch____,

STA. CRUZ SAVINGS AND DEVELOPMENT

COOPERATIVE,
Plaintiff,
- versus - Civil Case No. ______
- for -
SUM OF MONEY
__________________________________,
Defendant.
x--------------------------------x

COMPLAINT

PLAINTIFF, thru counsel, and to this Honorable Court, respectfully

alleges:

1. Plaintiff herein represented by its duly constituted Attorney-In-Fact

(Annex “A”) is a registered cooperative duly organized and existing under and by
virtue of Philippine Laws with principal office address at Poblacion Este, Sta.
Cruz, Ilocos Sur;

2. Defendant is also of legal age, and a resident of _____________,

__________________________, where ______ maybe served with Summons
and other Court processes;

3. Defendant is a member of Sta. Cruz Savings and Development

Cooperative (SACDECO for brevity). Sometime on ___________________, he
applied for a loan in the amount of ______________________________
(Php________________) PESOS, Philippine Currency as shown by copies of
the Loan Application Form/Disclosure Statement on Loan/Credit Transaction
hereto attached as Annexes “B” and “C” respectively;

4. The loan application was approved on ________________, and

the proceeds thereof was received by the defendant as shown by copies of the
Loan Release Order and Promissory Note hereto attached as Annexes “D” and
“E”;

5. Under the terms and conditions of the loan, defendant is under

obligation to pay monthly installment payments beginning or until
__________________;

6. That the loan obligation has lapse and the defendant defaulted in the
payment thereof and as of _________________, the total amount of the loan
including interest and penalties is now Php______________as shown by a copy
of the Statement of Account hereto attached as Annex “F”;

7. That despite demands the defendant failed and refused to settle his
obligation to the damage and prejudice of the plaintiff as shown by a copy of the
last letter of demand hereto attached as Annex “G”.

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 PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court to render judgment as follows:

a. Ordering the defendant to pay the amount of Php

__________________ including interest at the legal rate from the
date default until fully paid; and

b. To pay the cost of suit.

Other reliefs just and equitable under the above premises are likewise
prayed for.

Sta. Cruz , for _____________________, ____________________.

WILFREDO R. CORTEZ
Counsel for the Plaintiff
Sta. Cruz, Ilocos Sur
IBP No. 28105/1-17-18
PTR No. 8890557/1-4-18
Roll No. 33768
MCLE Compliance V-0013871
Issued at Pasig City
On February 11, 2016

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, EVA B. GARNACE-BORJA, of legal age, under oath, do hereby

depose and say:

That I am the representative and Attorney-In-Fact of the plaintiff in the

above entitled case;

That I have caused for the preparation of the foregoing Complaint upon
the authority of the Board of Directors hereto attached;

That all the allegations stated therein are true and correct and based on
genuine or authentic records;

That of my own personal knowledge plaintiff have not commenced any

other suit or proceeding involving the same issues before the Supreme Court, the
Court of Appeals, or any other tribunal or agency and should plaintiff shall
thereafter learn that a similar case has been filed or is pending before any of the
aforementioned Courts, she will undertake to report such fact five (5) days from
knowledge therefrom.

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 IN WITNESS WHEREOF, I have hereunto affixed my signature this
______ day of _______________, at Sta. Cruz, Ilocos Sur.

EVA B. GARNACE-BORJA
Affiant
Tin No. 147-157-262

SUBSCRIBED AND SWORN to before me this __________day of

_________________, affiant exhibited to me her Valid Identification as proof of
her identity.

_____________________
Notary Public

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