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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


National Capital Judicial Region
Quezon City, Branch __

JUAN TAMAD
Plaintiff,

- versus -
Civil Case No. ___________
For: Replevin
JUAN DELA CRUZ,
Defendant.
x---------------------------------------x

COMPLAINT

COMES NOW Plaintiff, JUAN TAMAD, by and through undersigned counsel,


unto this Honorable Court, most respectfully states that:

1. Plaintiff JUAN TAMAD is of legal age and with address at ____________,


where he may be served with summons and other court processes;
2. Defendant JUAN DELA CRUZ is of legal age, and with address at
____________, where he may be served with summons and other court
processes.;
3. Plaintiff is the lawful owner of _________, a personal property, valued at
__________ and more particularly described as follows:
(description of property)
4. On _________, herein defendant borrowed said property from Plaintiff
promising to return the same;
5. On _________, the herein Plaintiff demanded for the return of the said
property but despite repeated demands, said Defendant refused;
6. The plaintiff hereby applies for an order for the delivery of said ____, and
hereby files the necessary affidavit and bond;
7. Herein Plaintiff executed a bond in double the value of the property in favor of
the Defendant if the return thereof be adjudged and for the payment to the
Defendant of such sum as he may recover in this action.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that:


a. The property in question be ordered delivered to the plaintiff
b. The defendant be made to pay the costs of this suit.
c. Plaintiff be granted such other equitable relief consistent with law and equity

(VERIFICATION WITH CERTIFICATION OF NON-FORUM SHOPPING)