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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
BRANCH 196
LAS PINAS

JOHN TILETILE
Plaintiff,
Civil Case No.
77777
For: Complaint
for Collection of
Sum of Money,
Revocation of
Contract, and
Issuance of Writ
of Replevin
-versus-

DAVID SALVADOR
Defendant,

X-------------------------x

COMPLAINT

PLAINTIFF, by undersigned counsel and to this Honorable Court,


respectfully states:

1. The Plaintiff John Tiletile is of legal age, single, and a resident


of 3 Wade St., NBA Subdivision, Manila City, and Defendant
David Salvador is of legal age. Single and a resident of 2 Doncic
St. NBA Subdivision, Manila City;

FIRST CAUSE OF ACTION

2. On November 5, 2019, Defendant obtained a loan from the


plaintiff in the amount of TWO HUNDRED THOUSAND
PESOS (P200,000.00) payable on or before March 31, 2020, as
evidenced by their Contract of Loan, a copy of which is hereto
attached as “Annex A”, and made a part of this complaint;

3. Upon the lapse of the period for the payment of the loan, and
despite numerous demand letter sent by the Plaintiff, as
evidenced by the Demand Letters dated  April 2, 2020, April 7,
2020 and April 15, 2020, herein attached as “Annex B”, “Annex
C”, and “Annex D” respectively, and made a part of this
complaint, the Defendant failed to pay the amount stated in the
Contract of Loan;

SECOND CAUSE OF ACTION

4. On November 22, 2019, Defendant acquired another loan from


the plaintiff in the amount of SEVEN HUNDRED THOUSAND
PESOS (P700,000.00) payable on or before April 30, 2020, as
evidenced by their Contract of Loan, a copy of which is hereto
attached as “Annex E”, and made a part of this complaint

5. Upon the lapse of the period for the payment of the loan, and
despite numerous demand letter sent by the Plaintiff, as
evidenced by the Demand Letters dated  May 5, 2020, 2020 and
May 10, 2020, herein attached as “Annex F” and  “Annex G”
respectively, and made a part of this complaint, the Defendant
failed to pay the amount stated in the Contract of Loan;

THIRD CAUSE OF ACTION

6. On December 6, 2019, Plaintiff and Defendant entered into a


contract of sale wherein the latter sold to the former his 2002
Mitsubishi Lancer Evolution VII, for NINE HUNDRED
THOUSAND PESOS (P900,000.00), payable on May 15, 2020,
and the car to be delivered upon perfection of the contract, as
evidenced by the Contract of Sale, herein attached as “Annex
H”, and made a part of this complaint;

7. Upon the lapse of the date for the payment of the car, it was not
yet delivered and the payment was not made, despite
numerous demand letters sent by the Plaintiff to the Defendant,
as evidenced by the Demand Letters dated May 20, 2020 and
May 31 2020, herein attached as “Annex I” and “Annex J”,
respectively, and made a part of this complaint;

FOURTH CAUSE OF ACTION

8. The Plaintiff entered into a Contract of Sale with the Defendant


as stated in the Third Cause of Action;
9. That due to the refusal of the Defendant to deliver the car back
to the Plaintiff which is subject of the Contract of Sale, which
stipulates that upon non-payment of the amount stated in the
Contract upon the date when it becomes due, the Defendant is
to return the car to the Plaintiff.

WHEREFORE, it is respectfully prayed that judgment be


rendered in favor of the plaintiff, and that:
1. Payment of the amount of the sum of NINE HUNDRED
THOUSAND PESOS (P900,000.00) with legal interest on
each loan, until paid;
2. Cancellation of the Contract of Sale with the Defendant;
3. The grant of a Writ of Replevin to have possession of the
car during the pendency of the car, in relation to the
stipulation stated in the Contract of Sale.
4. That the Defendant pay the costs of the suit and Plaintiff
be granted other such equitable reliefs as consistent with
law and equity.

CITY OF MANILA, June 17, 2020

Atty. William Kyle C. Santos


Counsel For Plaintiff
Unit 1715, ABC Building, Las Pinas City
Roll No: 987654: 5/28/2019
IBP No. 456123:7/1/2019 - Las Pinas
PTR No. 741258:1/1/2020 - Las Pinas
VERIFICATION AND CERTIFICATION OF NON-FORUM
SHOPPING

REPUBLIC OF THE PHILIPPINES)


CITY OF LAS PINAS                )S.S.

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 the fact
within five (5) days to the court or where the complaint or
initiatory pleading has been filed.

CITY OF LAS PINAS, June 17, 2020

(Sgd) John Tiletile


Affiant
JURAT

SUBSCRIBED AND SWORN to before me, this 17th of June, 2020, in


the City of Manila by VJ Pangan, with Passport No. EB78945 issued
on January 1, 2015, at DFA Manila.

(Sgd) Atty. William Kyle C. Santos


Notary Public for Las Pinas
Commission Serial No. 123456
Until December 31, 2020
IBP No. 456123:7/1/2019 - Las Pinas
PTR No. 741258:1/1/2020 - Las Pinas

Doc. No. 79;


Page No.11;
Book No.II;
Series of 2020;

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