REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT Branch I, Lapulapu City
ABC Rent-A-Car (Philippines), Inc., Plaintiff, - versus 112098
Civil Case No.
John Doe, Defendant.
For: For: Replevin Replevin
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COMPLAINT
Comes now, the Plaintiff, through the undersigned counsel, and to this Honorable Court alleges: 1. That Plaintiff is a domestic corporation existing existing under the laws of the Philippines, with offices at 311 P. Del Rosario St., Lapulapu City, while defendant is an American citizen, residing at Room 1024, Crown Regency Hotel, where he may be served with Summons; 2. That plaintiff is the registered registered owner of a motor vehicle described as a Mitsubishi Lancer, model 1984, with Plate No. DAY-203; 3. That on January 11, 2012, defendant rented from plaintiff plaintiff said Lancer car for a week from January 11 to 18, 2012; 4. That January 20, 2012, and for the next three (3) days thereafter, thereafter, plaintiff demanded from defendant the return 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 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. Lapulapu City, March 05, 2012
ATTY ATTY.. JANE DEER XYZ Building, Manila IBP No. 12345; 1/3/2000;
Manila PTR No.61879; 2/2/2000;
Manila Roll of Attorneys No. 12344
