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d by the latter on the date agreed upon. Prepare the verified complaint for replevin.

Sign as
Atty. Asunto.

Answer:

REPUBLIC OF THE PHILIPPINES


NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Branch I, Manila

Avis Rent-A-Car (Philippines), Inc.,


Plaintiff,

- versus - Civil Case No. 112098

JOHN DOE, For: Replevin


Defendant.
x--------------------------------x

COMPLAINT

Plaintiff, by counsel, respectfully alleges:

1. That Plaintiff is a domestic corporation existing under the laws of the Philippines, with offices
at 311 P. Casal St., Quiapo, Manila, while defendant is an American citizen, residing at Room 1024,
Manila Hotel, where he may be served with Summons;

2. That plaintiff is the registered owner of a motor vehicle described as a Mitsubishi Lancer,
model 1984, with Plate No. DAY-203;

3. That on October 11, 1986, defendant rented from plaintiff said Lancer car for a week from
October 11 to 18, 1986;

4. That on October 20, 1986, and for the next three (3) days thereafter, plaintiff demanded from
defendant the return of the said car; but defendant avoided returning the car by giving one reason or
another;

5. That said car has not been taken for a tax assessment or fine pursuant to law, or seized on
execution or attached;

6. That the value of the said car is P290,000;

7. That plaintiff is ready and willing to give bond executed to the defendant in double the value
of the property for the return of the property to the defendant should be adjudged, or for the payment of
such sum that defendant may recover from plaintiff in the action.

WHEREFORE, plaintiff prays that:


1. The sheriff or other proper officer be ordered to take possession of the car and dispose of it in
accordance with the Rules of Court;
2. After hearing, judgment be rendered declaring that plaintiff is entitled to the possession of the
car or, should this prove unavailing, sentencing defendant to pay the value of the car.
Manila, December 3, 1986.

ATTY. ASUNTO
XYZ Building, Manila
IBP No. 12345; 1/3/1986;Manila
PTR No.61879; 2/2/1986; Manila
Roll of Attorneys No. 12344

VERIFICATION
I, RAPHY GAYONA, subscribing under oath, hereby deposes and states that:

I am the plaintiff in the instant case.

I have read the foregoing Complaint and the allegations therein are true and correct of my own
knowledge and/or based on authentic records on hand.

I attest to the authenticity of the annexes thereof.

RAPHY GAYONA

CERTIFICATION

I certify that:

a. I have not commenced any other action or proceeding involving the same issues in the
Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or
agency.

b. No such action or proceeding is pending in the Supreme Court, the Court of Appeals, or
different Divisions thereof, or any other tribunal or agency.

c. If I should learn that a similar action or proceeding has been filed or is pending before the
Supreme Court, the Court of Appeals, or different Divisions thereof, or any other tribunal or
agency, I hereby undertake to notify this Honorable Court within five (5) days from such
notice.

RAPHY GAYONA
Affidavit

I, , of legal age, single, and a resident of , being sworn in accordance with law depose
and say:

1. That I am the plaintiff in an action for the delivery of personal property against
the defendant, entitled ___ in the Regional Trial Court of ____;
2. That I am the owner of said property, particularly described as follows, to wit:
3. That the said personal property is wrongfully detained by the defendant without
any lawful cause whatsoever;
4. That the said personal property has not been taken for a tax assessment or fine
pursuant to law, or seized under an execution, or an attachment against the
property of the plaintiff;
5. That th actial value of the property is ___

Plaintiff

SUBSCRIBED AND SWORN to before me this 26 th day of September, 1992 by MARY VANILLA,
exhibiting to me her Community Tax Certificate No. 12346 issued at Quezon City on January 4, 1992.

LAWRENCE VILLEGAS
Notary Public
Until December 31, 1992
PTR No. 61879; 1/2/1992;Q.C.
IBP No. 112098; 2/2/1992; Q.C.
Roll of Attorneys No. 12344

Doc. No. 10;


Page No. 20;
Book No. V;
Series of 1992.