Professional Documents
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} S. S.
-versus-
HIMCHAN KIM
Defendant,
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - x
Replevin
Plaintiff through the undersigned counsel, and unto this Honorable Court, respectfully
avers that:
1. Both the plaintiff and the defendant are of age, and residents of Quezon City;
That the automobile was only rented to the defendant herein, upon the premise that
weekly payments shall be made from the date that it was leased. The agreement
started on June 10, 2013 but after the first two weeks, payments have stopped and the
defendant has refused to return the property. That to this date, 10 th of September 2013,
the property has yet to be returned.
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 legis.
4. The plaintiff herein has demanded of the defendant the delivery of 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 to the latter if such
return be adjudged and for the payment of such sum as the defendant may recover in
this action.
IN WITNESS WHEREOF, I have hereto have hereby set their hands on the 10 th day of
September 2013, in Quezon City, Metro Manila
________________________
Michelle Anne B. Recto
Conforme:
________________________
Atty. Yongguk Bang
__________________________
Zelo Choi
________________________
Daehyun Jung
ACKNOWLEDGEMENT
Identifying Instrument
known to me and to me known to be the same person/s who executed the foregoing
Replevin consisting of 5 pages including the page on which this Acknowledgment is
written, and who acknowledged to me that the same is their free and voluntary act and
deed.
WITNESS MY HAND AND SEAL this 10th Day of September, 2013, at Quezon City,
Philippines.
YOUNGBAE DONG
Notary Public
Attorneys Roll No.: 24315672
PTR No.: 85764 01/01/2010
IBP N. 5637658, 01/01/2010
MCLE Compliance No.: 9875
Quezon City, Philippines
I, MICHELLE ANNE B. RECTO, of legal age, after having been duly sworn in
accordance with law, depose and state that:
1. I am the defendant in the above-stated case;
2. I caused the preparation of the foregoing answer;
3. I have read the contents thereof and the facts stated therein are true and correct of my
personal knowledge and/or on the basis of copies of documents and records in my
possession;
4. I have not commenced any other action or proceeding involving the same issues in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or proceeding is pending in
the Supreme Court, the Court of Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to this Honorable
Court.
________________
Affiant
SUBSCRIBED AND SWORN to before me this 10th day of July 2013, at the City
of Manila, affiant exhibiting to me his Community Tax Certificate No. 125256 issued on
September
10,
2013
at
the
City
of
Manila,
Philippines
Doc. No. ;________
Page No. ;________
Book No. ;________
Series of 2013.