REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 1
Manila

JUAN DELA CRUZ,

Plaintiff,
Civil Case No. 345
-versus- For: Replevin

MARIA REYES,
Defendant.
x-----------------------------------------x

COMPLAINT

Plaintiff by the undersigned attorney and unto this Honorable Court respectfully
avers that:

1. Plaintiff and defendant are of age residents of 3 Tayuman St., Tondo, Manila
and 4 Tayuman St., Tondo, Manila respectively;
2. Plaintiff is the owner of a certain personal property, namely, Hyundai Starex
valued at P700,000.00 and more particularly described as follows, to wit:

A motor vehicle namely a 4-cylinder 1999 Hyundai STAREX Van that

plaintiff rented to defendant on January 4, 2015 to be used in plaintiff’s
company outing, which van defendant failed to return on the same day
agreed upon by both parties.

3. The said property has not been distrained or taken for a tax assessment or a
fine pursuant to law, or seized under a writ of execution or preliminary
attachment, or otherwise placed under custodial egis, or if so seized, that is
exempt from such seizure or custody.
4. The plaintiff has demanded of the defendant the delivery of the said property
but the latter refused and continues to refuse to do so; and
5. Plaintiff hereby executed a performance bond in double the value of the
subject property, in favor of the defendant, for the return of the property ot the
latter if such return be adjudged, and for the payment of such sum as the
defendant may recover in the action.

WHEREFORE, it is respectfully prayed:

(a) That the property in question be ordered delivered to the plaintiff;
(b) That defendant be made to pay the costs or this suit;
(c) And that plaintiff be granted such further relief consistent with law and equity.

City of Manila, March 7, 2016.

 ATTY. JUANICO FRANCISCCO
Counsel for Defendant
Unit 1, X Building, Recto, Manila
IBP No. 123456; 01/10/10 – Manila
PTR No. 1234567; 01/10/10 – Manila
Roll No. 12345; 5/05/05
MCLE No. I – 001234; 9/09/09
MCLE No. II – 115678; 9/09/09

VERIFICATION AND CERTIFICATION