REPUBLIC OF THE PHILIPPINES

SUPREME COURT OF THE PHLIPPINES

EIGHT JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 37
Naval, Biliran

CORPIN, CHRISTIAN ALFRED G. Civil Case Number: N-12345

Plaintiff,
For: Replevin
- Versus -

DELA CRUZ, JUAN

Defendant,
x---------------------------------------------/

COMPLAINT

Plaintiff by the undersigned attorney, and unto this Honourable

Court, respectfully avers that;

1. Both the Plaintiff and the Defendant are of legal age, and
residents of Caibiran, Biliran;

2. Plaintiff is the owner of a Honda Civic valued ONE MILLION

PESOS (PHP 1,000,000,00) and more particularly described as
follows:

MAKE: HONDA
MODEL: CIVIC
BODY TYPE: 4 DOOR SEDAN
ENGINE NO.: 123456
CHASSES NO.: 123456
PLATE NO.: ABC1234
COLOR: BLACK
MODEL YEAR: 2019
OWNER: CHRISTIAN ALFRED G. CORPIN

3. Sometime on January 1, 2019, Defendant borrowed the

mentioned car for his personal use because his car was
subjected for repairs.

4. Out of mercy and compassion, Plaintiff allowed defendant to

borrow and use his car for only up to August 1, 2019.
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 5. Defendant obliged himself to return the car on August 1, 2019.

6. When August 1, 2019 came, Plaintiff asked Defendant to return

the car. However, Defendant refused to return his car.

7. On August 2, 2019, Plaintiff sent a demand letters asking

Defendant to return the car, but Defendant ignored the demand
letters.

8. Defendant is detaining Plaintiff’s car in his garage and will not

return it.

9. The said property has not been detained 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, or if so seized, that is exempt from such seizure
or custody.

10. The Plaintiff has demanded of the Defendant the delivery

of said property, but the latter refused and continues to refuse to
do so, and

11. Plaintiff hereby executed a performance bond in double the

value of the subject property, in favour 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 his
action.

WHEREFORE, it is respectfully prayed:

a.) That the property in question be ordered delivered to the Plaintiff;
b.) That Defendant be made to pay the costs of this suit;
c.) And that Plaintiff be granted such further relief consistent with law
equity.

November 4, 2019 at Naval, Biliran.

MAGTATANGGOL LAW OFFICE

Counsel for the Plaintiff
ABC St. Naval, Biliran.
Naval, Biliran 6560

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 Tel. No. (053) 500 1234

By:

ATTY. EMER JOHN C. SARI

Cellphone No.: 09123456789
E-mail address:
sarilawoffice@gmail.com
Roll No.: 12345
IBP No.:12345
PTR No.:12345
MCLE Com.:12345 Issued on
1/07/19

REPUBLIC OF THE PHILIPPINES )

PROVINCE OF BILIRAN )
MUNICIPALITY OF NAVAL )

CERIFICATION AND CERTIFICATION

OF NON-FUROM SHOPPING

I, CHRISTIAN ALFRED G. CORPIN, after having been sworn to in

accordance with law, hereby depose and say:

1. That I am the Private Complainant in the above entitled case and

have caused this Complaint Affidavit to be prepared;

2. That I read and understood its contents which are true and
correct of my own personal knowledge and/or based on authentic
records;

3. That I have not commenced any action or proceeding involving

the same issue in any court, tribunal, or agency;

4. That to the best of my knowledge, no such action or proceeding

is pending in any court, tribunal, or agency; and

5. That, if I should learn thereafter that a similar action or

proceeding has been filed or is pending before the courts,
tribunal, or agency. I undertake to report that fact to this
Honourable Court within five (5) days therefrom.

IN WITNESS WHEREFORE, I have hereunto set my hand this 4th day

of November 2019 at Naval, Biliran.

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 CHRISTIAN ALFRED G. CORPIN
Affiant
Driver’s License
H1234567

SUBSCRIBED and SWORN to before me, in the municipality of

Naval, Bliran, this 4th day of November 2019 by CHRISTIAN ALFRED
G. CORPIN.

I certify that have personally examined the herein affiant and that
I am fully satisfied that he executed and understood the contents of his
Complaint Affidavit, having explained the contents of the same in a
dialect which is known and understood by him, and that the same is
his voluntary free act and deed.

Doc. No.:______,
Page No.:______,
Book No.:______,
Series of 2019
NOTARY PUBLIC:
Commission Serial No.:____
Until December 31, _______
Roll of Attorney __________
IBP No.:___/Date/Place of issue
PTR No.: __/Date/place of issue

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