REPUBLIC OF THE PHILIPPINES

Republic of the Philippines

National Capital Judicial RegionREGIONAL TRIAL COURTCity of ManilaBranch ____LEGASPI TOWERS 300 inc. represented by JESSIE JOHN P. GIMENEZ,Plaintiff,

- versus -CIVIL CASE NO. __________

For: Sum of Money

SONJA RODRIGUEZ,

Defendant.

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COMPLAINT

COMES NOW Plaintiff, by counsel, unto this Honorable Court, most respectfully states that:1. Plaintiff is a condominium corporation duly organized and existing under the laws of the Philippines, having its principal office at 2600 Roxas Blvd., corner Pablo Ocampo (formerly Vito Cruz) Street, Malate, Manila;2. Defendant is Sonja Rodriguez, married, of legal age, Filipino, whose last known address is at the 5th floor, Unit H and I, 2600 Roxas Blvd., corner Pablo Ocampo (formerly Vito Cruz) Street, Malate, Manila;3. In the period of December 2008 to May 2015, the defendant defaulted in paying Association Dues, Electric and Water bills to the plaintiff totaling to Nine Hundred Twenty Six Thousand Two Hundred Sixty Nine & 93/100 Philippine Currency (PHP 926,269.93), inclusive of a 2.5% penalty on Delinquent Accounts. Such an amount constitutes a debt on the part of the defendant based on the June 1, 2015 Consolidated Bill hereto attached as Annex A.4. Despite demands by plaintiff, defendant failed to respond or pay the debt as evidenced by the Demand Letters sent by the undersigned Legal Counsel, dated June 23, 2015, July 15, 2015 and August 3, 2015 Photocopies of which are hereto attached as Annex B, Annex C, and Annex D and made an integral part hereof.

P R A Y E R

WHEREFORE, it is most respectfully prayed of this Honorable Court that after due hearing, judgment be rendered in favor of plaintiff and against the defendant in this manner.1. Ordering the defendant to pay plaintiff the amount of Nine Hundred Twenty Six Thousand Two Hundred Sixty Nine & 93/100 Philippine Currency (PHP 926,269.93), with legal rate of interest, compounded from July 23, 2013, and until the same is fully paid;2. Issuing a Writ of Preliminary Attachment to Unit H and I on the 5th floor of, 2600 Roxas Blvd., corner Pablo Ocampo (formerly Vito Cruz) Street, Malate, Manila as security for the settlement of this case; and

3. Ordering the defendant to pay the cost of this suit and attorneys fees.

Plaintiff likewise prays for such other reliefs as this Honorable Court may deem just and equitable.Makati City for Manila City, July 15, 2015.

JERICO D. SALENGA

IBP No. 0987838/1-8-15/Makati CityPTR No. 4754780/1-8-15/Makati CityRoll of Attorney No. 63010

MCLE Compliance No. Exempted

Suite 2311 Cityland 10 Tower II, 154 H.V. Dela Costa St.,

Salcedo Village, Makati City 1227, Philippines

Tel. No: 753-2234

Cell No.: 091 555111 27

Email: jericosalenga@gmail.comCopy furnished:

SONJA RODRIGUEZDefendant5th floor, Unit H and I,

2600 Roxas Blvd.,

corner Pablo Ocampo Street,

Malate, ManilaEXPLANATION

In compliance with Section 11, Rule 13 of the 1997 Rules of Civil Procedure, the undersigned counsel states that due to distance, time and manpower constraints, personal service of this Complaint was not resorted to and instead, copies of the same were sent by registered mail pursuant to Section 7, Rule 13 of the said rules as per attached registry receipt(s).JERICO D. SALENGAVERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, Jessie John P. Gimenez, of legal age, President of Legaspi Towers 300 Inc. located at 2600 Roxas Blvd., corner Pablo Ocampo (formerly Vito Cruz) Street, Malate, Manila, under oath, do hereby depose states that:1. I am the complainant in the said case;2. I have caused the preparation of the same and I attest to the veracity of all the allegations stated herein;3. I have read and understood all the allegations herein and that I attest to the authenticity and veracity of all the documents attached herein as based on existing and authentic records;4. I further certify that I have not commenced or filed any claim involving the same issues herein with any other Court. Tribunal or Quasi-Judicial Agency or I am not aware of any such other case or claim pending before any other court, tribunal or quasi-judicial agency; and5. Should I thereafter learn of the filing or pendency of such similar action or claim, I will inform this Honorable Court of such fact within five (5) days from knowledge thereof.

IN WITNESS WHEREOF, I have hereunto affixed my hands this 15th day of July, 2015 at Makati City, Philippines.

JESSIE JOHN P. GIMENEZAffiant

SUBSCRIBED and SWORN TO before me this 15th day of July, 2015 at Makati City, Philippines, affiant exhibiting to me her Drivers License issued on ___th day of _______ 2015 at Makati City, Philippines.

NOTARY PUBLIC

Doc. No. __________

Page No. __________

Book No. __________

Series of 2015PAGE 5