Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Makati City, Branch 12

ADVENT FINANCE CORPORATION,

Plaintiff,
-versus-

Civil Case No. 88

For: Recovery of
Possession
of
Personal
Property

ROLAND YOUNG,
Defendant.
x----------------------------------x
COMPLAINT
The
Plaintiff,
through
counsel,
and
unto
Honorable Court, most respectfully states that:

the

1.Plaintiff, is a corporation duly organized and

existing under the laws of the Philippines with
office address at Makati Avenue, Makati City, where
it may be served with summons and other court
processes;
2.Defendant, is a Filipino, of legal age, and with
address at Bel-Air Village, Makati City, where he

may be served with summons and other court

processes;
3.Plaintiff, is the lawful owner of a 1996 Mercedes
Benz E230 with plate number UMN-168, which is
registered
in
its
name,
evidenced
with
a
Certificate of Registration, attached herewith as
annexed A;
4.Defendant, is a former employee of the plaintiff,
with a position of General Manager, to which the
subject personal property hereof, was assigned,
based on a car plan that the company has for its
employees;
5.Upon the Courts approval of the Rehabilitation
Plan submitted by Plaintiff, on August 15, 1996,
the said personal property, is included in the list
of the Plaintiffs assets;
6.Plaintiff, demanded the return of said personal
property , but despite repeated demands, Defendant
refused and still refuses to return said property;
7.Said property has not been taken from Plaintiff for
tax assessment or fine pursuant to law, or seized
under an execution, or attachment against the
property;
8.That the actual value of said property is One
Million
Five
Hundred
Thousand
Pesos
(P1,500,000.00), Philippine currency;
9.Plaintiff is ready and willing to file a bond,
executed to the Defendant in double the value of
the property stated above, for the return of the
property to the defendant if the return thereof be
adjudged and for the payment to the defendant as
such sum as he may recover from plaintiff in the
action;
WHEREFORE, Plaintiff prays for the judgment:
1.Ordering
the Sheriff to take such property into
his custody and to dispose of it in accordance with
the Rules of Court;

2.After trial of the issues, adjudging that the

Plaintiff has the right to the possession of said
personal property and rendering judgment in the
alternative against the defendant for the delivery
thereof to the Plaintiff of the value in case
delivery cannot be made;
3.Ordering the defendant to pay the costs of this
suit and for such other equitable relief in the
premises.
Makati City, Philippines, January 29, 2015.

Concepcion T. Cejano
Counsel for Plaintiff

VERIFICATION
JURAT