Vous êtes sur la page 1sur 2



) S.S.


KRITSANA KAEWMANEE , 30, and of legal age and a resident of
325K Ascension Street Urgello Cebu City in the Province of Cebu, Philippines, after
having been duly sworn to in accordance with law, hereby deposes and says:

1. That Kritsana Keawmanee is a Medical Student of Cebu Institute of Medicine.

She has been living in that neighborhood since July of 2013;

2. That later on the year of 2013 Mr. Hassim Ditingki, a Thai international Medical
Student from Cebu Institute of Medicine moved to a room adjacent to where Miss
Kaewmanee has been living. Since then, they became friends and even got

3. That on December 16th of 2014, a fire gutted in their neighborhood where almost
all of the houses were burnt down. Unfortunately, Mr. Ditingki was not at home
during the fire hence Miss Kaewmanee as his good friend managed to take care
of some of Mr. Ditingkis things left from the which resulted to her minor burns;

4. That by virtue of the maxim that no one shall be unjustly enriched at the expense
of another, Miss Kaewmanee is asking for payment for damages that she
suffered from that incident and retained for keeping the things of Mr. Ditingki;

5. That in the light of our obligations and contracts law, an obligation is created in
the absence of the agreement between the parties where unjust enrichment is
invoked which occurs when a person retains money or benefits that in all fairness
belong to another, would exist without judicial relief. Thus, a quasi-contract exists
between Miss Kaewmanee and Mr. Ditingki;

6. That Mr. Ditingki refuses to give any amount as a form for any damages to Miss
Kaewmanee and expressly advised her that he is not coming back to the
Philippines to continue his studies;

7. That she is the Plaintiff in the above-entitled case; being the aggrieved party;
8. That there is sufficient cause of action; under Section 1 of Rule 57 specifically
enumerates the statutory grounds for the issuance of the writ of preliminary
attachment, involving the following cases:

In an action for the recovery of a specified amount of money or damages,

other than moral and exemplary, on a cause of action arising from law,
contract, quasi-contract, delict or quasi-delict against a party who is about
to depart from the Philippines with intent to defraud his creditors.

9. That she is filing a bond equivalent to Php 75,000.

That the amount claimed in the action is as much as the sum which the order is
prayed for above all legal counterclaims.


Kritsana Kaewmanee

SUBSCRIBED AND SWORN to before me this day of May 6, 2015 the, affiant is
personally known to me and exhibiting to me his Passport No. 123456 issued at
Legaspi City, Philippines on January 3, 2012.

Doc. No. 1;
Page No. 1;
Book No. 1;
Series of 2015;