Republic of the Philippines
______ Judicial Region
REGIONAL TRIAL COURT
City of_______
Branch ___
NAME OF PLAINTIFF,
Plaintiff,
-versus- CIVIL CASE NO. ___________
For: Foreclosure of Real Estate
Mortgage
NAME OF DEFENDANT,Defendant.
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COMES NOW Plaintiff, by undersigned counsel, respectfully alleges - THAT:
1. Plaintiff is of legal age, Filipino, single, and a resident of (Place of Residence);
2. Defendant is of legal age, Filipino, single, citizen, and a resident of (Place of Residence), where he may be served with summons and other processes by this Honorable Court;
3. On (Date), defendant borrowed from plaintiff money in the amount of (Amount in Words (Amount in Figures), which was evidenced by a promissory note on the same date, promising to pay the plaintiff the said amount with legal interest, on or before (Date). Copy of the promissory note is hereby attached as ANNEX “A” of this complaint;
4. To secure the payment of said loan, defendant mortgaged a certain parcel of land covered by TCT No. __________ issued by the Register of Deeds of the City of _________, hereto attached as ANNEX “B”, which is more particularly described as follows:
Description of Property with Technical Details
5. The terms and conditions of said mortgage are incorporated in a Real Estate Mortgage executed and signed by defendant on (Date). Copy of the Real Estate Mortgage is attached hereto as ANNEX “C”;
6. The mortgage debt is now long overdue, but defendant failed, and still fails, to pay the same, or any part thereof, notwithstanding demands of plaintiff. Copy of the demand letter is hereto attached as ANNEX “D”;
7. There are no other persons having or claiming an interest in the mortgaged property.
WHEREFORE, premises considered it is most respectfully prayed that judgment be rendered against the defendant:
a) To pay within a period of not less than ninety (90) days but not more than one hundred twenty (120) days from entry of judgment, the sum of (Amount in Words) (Amount in Figures) together with the stipulated interest, plus cost of suit and attorney’s fees; and
b) In default of such payment, the aforementioned property be ordered sold at public auction to pay off the mortgage debt and its accumulated interest, plus attorney’s fees and cost of suit.
Other reliefs just and equitable are likewise prayed for.
(Place of Filing), (Date of Filing).
LAWYER DETAILS
VERIFICATION/CERTIFICATION AGAINST FORUM SHOPPING
