COMES NOW the plaintiff by the undersigned counsel and unto this Honorable

Court, respectfully states:

      1. That both the plaintiff and the defendant are of legal age and residents of ______________ and _____________, respectively,

      2. That on __________, the defendant, in order to secure the payment of the sum of ___________, acknowledged to have been received by him on said date, executed in favor of the plaintiff a first mortgage on certain real property located in ________, and duly registered with the Register of Deeds of ______, a true copy of said Deed of Real Estate Mortgage is hereto attached as Annex "A" and made an integral part of this complaint;

      3. That the condition of said mortgage, as stated therein, is such, that if within the period of _______ from and after the execution of same, the defendant shall pay or cause to be paid to the plaintiff, his heirs, or assigns, the said sum of __________, together with the stipulated interest of ______% per annum, then the said mortgage shall be discharged, otherwise, it shall remain in full force and effect, to be enforceable in the manner prescribed by law;

      4. That the defendant has not paid or caused to be paid the mortgage debt of ___________ or any part thereof, in spite of the lapse of the stipulated period;

      5. That the plaintiff has demanded of the defendant to pay the above sum of P_________ , plus the stipulated interest, but said defendant has failed, up to the present, to pay the same;

      6. That the defendant has also agreed in the mortgage contract (Annex "A") that should the plaintiff foreclose the mortgage, the latter is entitled to receive the further sum of _________% of the total amount due as attorney's fees, expenses and costs;

      7. That there are no other persons having or claiming an interest in the mortgaged property.

      WHEREFORE, it is most respectfully prayed:

           (a) That, upon due hearing, judgment he rendered: (1) ordering the defendant to pay unto the court within the reglementary period of ninety (90) days the sum of P_______, together with the stipulated interest at _____% per annum from and after _________, plus the additional sum of _______% of the total amount due as attorney's fees, expenses and costs; (2) and that in default of such payment, the above-mentioned property be ordered sold to pay off the mortgage debt and its accumulated interest, plus ______% of the total amount due as attorney's fees, expenses and costs.

           (b) That plaintiff be granted such other relief in law and equity.

      Makati City, this ______ day of ___________, 2004.