Professional Documents
Culture Documents
-versus-
Collection of Sum of
Money with Damages
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Complaint
2. The Plaintiff never gave the defendant the alleged amount of Three
Hundred Fifty Thousand Pesos (350,000.00); that Defendant did
not sign the alleged promissory note; and that Defendants
signature is forged.
3. On November 5 and November 6, 2015, the Defendant and the
Plaintiff did not see each other because the former visited her late
grandmother in San Pedro, Laguna as evidenced by the photocopy
of entry/exit of vehicles monitoring sheet, attached herein, marked
as Annex B, and made an integral part hereto. Such monitoring
sheet is issued by the Gate Security Department of the Subdivision
where the Defendant resides.
COMPULSARY COUNTERCLAIM
1. By reason of the abuse of right committed by the plaintiff and by
reason of the instant precipitate and unfounded suit, the defendant
was constrained to hire the services of a lawyer to defend his rights
and interests for a professional fee of Twenty-Thousand Pesos
(20,000.00) and Three Thousand Pesos (3,000.00) per court
appearance;
2. Similarly, the plaintiffs unfounded suit has caused the defendant
mental anguish, wounded feelings, sleepless nights, serious
anxieties, and other similar sufferings for which the defendant
claims moral damages of One Hundred Thousand Pesos
(100,000.00).
PRAYER
WHEREFORE, PREMISES CONSIDERED, it is respectfully
prayed to this Honorable Court the dismissal of the complaint for
lack of merit with costs against the plaintiff; and that the
defendants compulsory counterclaim be granted, i.e., moral
damages of One Hundred Thousand Pesos (100,000.00), attorneys
fees of Twenty-Thousand Pesos (20,000.00), and Three Thousand
Pesos (3,000.00) per court appearance and costs of suit.
Other reliefs just and equitable under the premises are
likewise prayed for.
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Complaint
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Complaint
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Complaint
Doc. No.: 49
Page No.: 8
Book No.: II
Series of 2015
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Complaint