Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 101, Paranaque City

JR DELA CRUZ, Plaintiff, - versus DEONNA FERNANDEZ, Defendant. x----------------------------------- x COMPLAINT Civil Case No. 000088 For: Replevin

Plaintiff, by counsel, respectfully states that: 1. Both the plaintiff and the defendant are of age and residents of 3 Don Manolo Blvd, Alabang Hills Village, Muntinlupa. 2. Plaintiff is the owner of a certain personal property, namely, Toyota Vios valued at P700,000.00 and more particularly described as follows, to wit: A motor vehicle namely a 2006 Toyota Vios that the plaintiff rented to the defendant on January 4, 2014 to be used in plaintiffs company outing, which van defendant failed to return on the same day agreed by both parties. 3. The car has not been taken for a tax assessment or a fine pursuant to law nor has it been seized on execution or attachment. Or if so seized, that is exempt from such seizure. 4. The plaintiff has demanded of the defendant the delivery of said property but the latter refused and continues to refuse to do so; and 5. Plaintiff is ready, willing and able to give bond in defendants name in double the value of the property for the return of the property to defendant should that be adjudged or for the payment of such sum that defendant may recover from plaintiff in this action. WHEREFORE, plaintiff respectfully prayed: (a) That the writ of replevin issue directing the Sheriff or any other authorized officer to take possession of the car and dispose of it in accordance with the Rules of Court. (b) Judgment be rendered declaring plaintiff to be lawfully entitled to the possession of the car and sentencing defendant to pay its value. (c) The defendant be made to pay the costs of this suit.

City of Paranaque; 7 March 2014.

ATTY. POCHOLO CARLO AUGUSTO S. SEVILLA Counsel for Plaintiff 2 The Firm Laguna Street, Quezon City

VERIFICATION & CERTIFICATION AGAINST FORUM SHOPPING I, JR DELA CRUZ, of legal age, do hereby state that: I am the lawful owner of the property and in such capacity, caused this Complaint to be prepared; I have read its contents and affirm that they are true and correct to the best of my own personal knowledge; I hereby certify that there is no other case commenced or pending before any court involving the same parties and the same issue and that, should I learn of such a case, I shall notify the court within five (5) days from my notice. IN WITNESS WHEREOF, I have signed this instrument on 7 March 2014. JR DELA CRUZ Affiant

SUBSCRIBED AND SWORN TO before me in the City of Paranaque on this day of 7 March 2014, affiant exhibiting before me his Government Issued ID no. 123456789 issued on January 2, 2013 at Paranaque City.

ATTY. RISSIENNE GAMMAD Notary Public PTR No. MKT7654321; 01/03/14; Taguig IBP Lifetime Roll No. 00001; Taguig Roll of Attorneys No. 12345 MCLE Compliance No. V-1234567; 02/04/13

Doc. No. Page No. Book No. Series of 2014.