Republic of the Philippines

Cebu Judicial Region

REGIONAL TRIAL COURT

Branch 26

ABC,

Plaintiff,

-versus-

EFG,

Defendant.

x - - - - - - - - - - - - - - - - - - - - - - - - -x

SCA No 111

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff and defendants are all of legal age; plaintiff resides at GG Cebu CIty while defendants
reside at HH Cebu City and II Cebu City, respectively, where they may be served with pertinent
notices.

2. On 1 June 2007, plaintiff found a Gold Rolex Oyster watch, without knowing who its true owner
is. The watch is now in plaintiff’s possession. On or about 5 June 1999, defendants made similar
representations to plaintiff as to ownership of the watch.

3. Plaintiff, who claims no interest in the watch, cannot determine the conflicting claims of
defendants and thus seeks to compel defendants to interplead and litigate their several claims
between themselves.

WHEREFORE, it is respectfully prayed that this Honorable Court issue an order directing defendants to
interplead with one another to determine their respective rights and claims and to allow plaintiff to
recover his expenses for safekeeping and the costs of this suit, as first lien upon the subject matter
of this action.

Cebu City; 13 April 2007.

RALPH KEN BACALAN

Counsel for Plaintiff

 VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Manila                     ) S.S.

  I, ABC, of legal age, Filipino citizen, single and resident of Cebu City, after having been duly
sworn to in accord Nance with law do hereby depose and say:
1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and have read the allegations
contained therein;
3. The allegations in the said complaint are true and correct of my own knowledge and
authentic records;
4. I hereby certify that I have not commenced any other action or proceeding involving the
same issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no
such other action or claim is pending therein;
5. That if I should learn thereafter that a similar action or proceeding has been filed or is
pending, I hereby undertake to report that fact within five (5) days therefrom to the court or agency
where the original pleading and sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the foregoing facts and to
comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.
          IN WITNESS WHEREOF, I have hereunto affixed my signature this 24th of September 2019,
in the City of Manila.
                                                       
ABC

          SUBSCRIBED AND SWORN to before me this 11 th day of September, 2012, in the City of
Manila, affiant exhibiting to me his Driver’s License No. 12345 issued by the Land Transportation
Office on March 18, 2020 at the City of Cebu.

                                             ATTY. NO CASE
                                                     Notary Public
                            My Commission Expires Dec. 31, 2020
                          Roll of Attorney No. 34567
                   IBP No. 12345/2-5-12/Manila
                                      PTR No. 87654/12-22-11/Manila

Doc. No. 12
Page No. 2
Book No. 34
Series of 2020.