Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 12
Cebu City

Julieta L. Tarnate CIVIL CASE NO. 445

Plaintiff For: Replevin
Vs:
Percival T. Baluarte
Defendant
COMPLAINT

PLAINTIFF, by counsel, unto this Honorable Court respectfully states and prays that:

1. Both plaintiff and defendants are Filipinos, and at the legal age, residents of Brgy; Pardo,
Cebu City;
2. Plaintiff is the owner of a jeep, valued at twenty thousand (20,000), particularly
described as follows;

Make : MITSHUBISHI

Type of Body; JEEP

Motor No; 4G-87492

Chasis No; CGU-34897563-C

MV File No. ; 0840-13 687

3. Plaintiff has demanded of the defendant the delivery of the subject property but the
latter refused and continues to refuse.

WHEREFOR, it is prayed:

A. That the property in question be ordered delivered to the plaintiff; or,

B. If material delivery is not possible, that defendant be ordered to pay plaintiff its actual
value of ₱ 20, 000;
C. That defendant be made to pay the cost of this suit;
D. It is further prayed that plaintiff be granted such further relief consistent with law
equity.

Signed this 17th day of November 2019 in Cebu City.

Atty; Juan Dela Cruz

Counsel for Plaintiff
123 Burgos Street, Ormoc City
PTR No. 5609742
Nov. 16, 2019