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Republic of the Philippines

REGIONAL TRIAL COURT
8th Judicial Region
Branch ___, Maasin Southern Leyte


TOUR-JACK Rent-A-Car, Inc.,
Plaintiff,

- versus - Civil Case No. 112098

Jetzon T. Lee, For: Replevin
Defendant.
x--------------------------------x

COMPLAINT

COMES NOW, the Plaintiff, through the undersigned counsel,
and to this Honorable Court alleges:

1. That Plaintiff is a domestic corporation existing under the
laws of the Philippines, at Enage Stree, Maasin City, while defendant
is an Chinese citizen, residing at Room 6, Southern Comfort Hotel,
Maasin City where he may be served with Summons;

2. That plaintiff is the registered owner of a motor vehicle
described as a Mitsubishi Lancer, model 1984, with Plate No. DAY-
203;

3. That on August 11, 2014, defendant rented from plaintiff
said Lancer car for a week from August 11 to 18, 2014;

4. That on August 20, 2014, and for the next three (3) days
thereafter, plaintiff demanded from defendant the return of the said
car; but defendant avoided returning the car by giving one reason or
another;

5. That said car has not been taken for a tax assessment or fine
pursuant to law, or seized on execution or attached;

6. That the value of the said car is P290,000;

7. That plaintiff is ready and willing to give bond executed to
the defendant in double the value of the property for the return of the
property to the defendant should be adjudged, or for the payment of
such sum that defendant may recover from plaintiff in the action.

2

WHEREFORE, plaintiff prays that:

1. The sheriff or other proper officer be ordered to take
possession of the car and dispose of it in accordance with the Rules of
Court;

2. After hearing, judgment be rendered declaring that plaintiff
is entitled to the possession of the car or, should this prove
unavailing, sentencing defendant to pay the value of the car.

Maasin City, September 3, 2014.


JERRY W. TONGZON
Counsel for the Petitioner
PTR No. XXXXXX, , Hilongos, Leyte
Lifetime Member No. XXXXX, 2018,
Roll of Attorneys No. XXXX, TIN: MCLE
Compliance NO. III 000000,