REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11th JUDICIAL REGION
BRANCH XVI

JASON A. DIAZ,
Plaintiff,

- versus - Civil Case No. 123-100

For: Interpleader

DANICA TUAZON AND LEILA RAZONABLE,

Defendants.
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COMPLAINT

PLAINTIFF, thru counsel, respectfully avers that:

1. Plaintiff and defendants are all of legal age, and residents of Damosa,
Lanang, Davao City and Cabantian, Buhangin, Davao City;
2. Sometime on September 16, 2019, Plaintiff found a Necklace in
Bajada, Davao City, without knowing who is the true owner thereof;
3. Said personal property is now in plaintiff’s possession;
4. Sometime on December 27, 2019, the defendants presented
themselves to the plaintiff, each claiming to be the true and exclusive
owner of the property in question;
5. Plaintiff, who claims no interest whatsoever in the subject matter of
this action, cannot determine the veracity of the conflicting claims of
the defendants;
6. Plaintiff brought this action against the conflicting claimants to
compel them to interplead and litigate their individual claims among
themselves.

WHEREFORE, it is respectfully prayed of this Honorable Court:

1. To issue an order summoning the defendants to interplead with one

another in order to determine their respective rights and claims;
and
2. To allow plaintiff to recover his expenses of safekeeping, and cost
of suit, to be charged as the first lien upon the subject matter of this
action.
Other reliefs just and equitable are likewise prayed for.
 GRIDLIN A. MATILAC
Notary Public for Davao City
Commission Serial No. 2020-0379-2022
Until December 31, 2021
Attorney’s Roll No. 10772
PTR No. 7862245 B; 01-02-20; Davao City
IBP O.R. No. 024454; 01-02-20; Davao City

REPUBLIC OF THE PHILIPPINES)

CITY OF DAVAO ) S.S.

VERIFICATION AND CERTIFICATION

I, Jason A. Diaz, Filipino, of legal age residing at Damosa,

Lanang, Davao City, after being sworn to in accordance with law,
deposes and says that:

1. I am the Plaintiff in the above-entitled case;

2. The facts stated in the above complaint are true and correct to
the best of my knowledge and authentic records;

3. I have not commenced any action or filed any claim 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 in them; and

4. If I should learn that the same or similar action or claim has

been filed or is pending after its filing, I shall report that fact
within five (5) days from notice to the court or where the
complaint or initiatory pleading has been filed.

January 27, 2020

Davao City, Philippines

Jason A. Diaz
Affiant

SUBSCRIBED and sworn to before me, this 27th day of

January, 2020, in the City of Davao by Jason A. Diaz with Passport
No. 12345678 issued on March 21, 2017 at Tagum City, proved to
me on the basis of satisfactory evidence to be the person who
appeared before me.
 GRIDLIN A. MATILAC
Notary Public for Davao City
Commission Serial No. 2020-0379-2022
Doc. No. Until December 31, 2021
Page No. Attorney’s Roll No. 10772
Book No. PTR No. 7862245 B; 01-02-20; Davao City
Series of 2020 IBP O.R. No. 024454; 01-02-20; Davao City