RIOFLORIDO, LEA ANGELICA R.

PRAC 1

REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
REGIONAL TRIAL COURT
City of Manila
Branch 1


MR. ABC,
Plaintiff,

-versus- CIVIL CASE NO. 1234
For:Damages with prayer
MR. XYZ for the issuance of Writ of
Defendant, Replevin


x---------------------------x


COMPLAINT

COMES NOW, the plaintiff, through the undersigned attorney, and to this
Honorable Court respectfully alleges:

1. That plaintiff is of legal age, Filipino citizen, with postal address at 123 Sta.
Mesa, Manila;
2. That defendant XYZ, is of legal age, Filipino citizen, with postal address at
456 Pasig City, where he may be served with summons and other processes
by this Honorable court;
3. That said plaintiff is the lawful owner of the following described personal
property:
-two (2) units concrete mixers
-one (1) unit skid steer loader
-one (1) road roller
4. That the aforementioned personal properties of the plaintiff engaged in the
construction business are used by the latter for his construction projects.
5. That on June 1, 2014, defendant borrowed said personal properties from
plaintiff to be used by the former to his construction project in Laguna,
promising to return the same after two (2) months;
RIOFLORIDO, LEA ANGELICA R.
PRAC 1

6. That after the lapse of two (2) months which is August 1, 2014 and for
months thereafter, Plaintiff demanded from the defendant the return of the
said properties, but, despite, said repeated demands, said defendant refused
and still refuses to return said properties, gratuitously claiming that the same
belongs to him;
7. That said property has not been taking from said plaintiff for a tax assessment
or fine pursuant to law, or seized under an execution, or an attachment
against the properties of plaintiff;
8. That the actual value of the personal properties are 1,200,000.00;
9. That the plaintiff is ready and willing to give bond, executed to defendant in
double the value of property as stated above, for the return of the property to
defendant if the return thereof be adjudged, and for the payment to defendant
of such sum as he may recover from plaintiff in the action;

WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that judgment be rendered:

1.) Ordering the sheriff or other proper officer of the court forthwith to take
said properties into his custody, and to dispose of it in accordance with the
Rules of Court;
2.) After trial of the issues, adjudging that plaintiff has the right to the
possession of said personal properties; and rendering judgment in the
alternative against defendant for the delivery thereof to plaintiff, or for the
payment to plaintiff of the value thereof in case delivery cannot be made;
3.) Cost of suit.

Plaintiff prays for such relief just and/or equitable in the premises.

Manila, August 30, 2014.

Sgd. ATTY. LEA RIOFLORIDO
IBP No. 1234/1-12-12
PTR No. 1234/1-12-12/Mla.
Roll No. 12202
MCLE No. 12010
Tel. No. 713-14-68
RIOFLORIDO, LEA ANGELICA R.
PRAC 1

VERIFICATION/CERTIFICATION AGAINST FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES )
CITY OF MANILA ) S.S

I Mr. ABC, of legal age, Filipino citizen, single, after having been duly sworn to
in accordance with law do hereby depose and say:

1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and have read
the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or proceeding
involving the same issues in the Supreme Court, Court of Appeals, or any
other tribunal or agency;
5. That if I should thereafter learned that a similar action or proceedings has
been filed or is pending before the Supreme Court, Court of Appeals, or any
other tribunal agency, I hereby undertake to report that fact within five (5)
days there from to the court or agency wherein the original pleading and
sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the foregoing
facts and to comply with the provisions of Adm. Circular No. 04-94 of the
Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 30
th
day
of August 2014, in the City of Manila.

Sgd. MR. ABC






RIOFLORIDO, LEA ANGELICA R.
PRAC 1


SUBSCRIBED AND SWORN to before me this 30
th
day of August
2014 in the city of Manila, affiant exhibiting to me his SSS ID No. 123456
issued at Manila on October 2012.




ATTY. AAAAA
Commission No. 12344
Until December 2016
Office Address: Sta Ana, Mla.
IBP No. 1234/1-12-12
PTR No. 1234/1-12-12/Mla.
Roll No. 12202
MCLE No. 12010
Doc No. _____;
Page No. ____;
Book No. ____;
Series of 2014.





















RIOFLORIDO, LEA ANGELICA R.
PRAC 1



ATTESTATION CLAUSE OF LAST WILL AND TESTATMENT


ATTESTATION CLAUSE

The foregoing instrument, which is ordained, published, and declared to be
the Last Will and Testament of ABC, consisting of Three (3) pages, all consecutively
numbered in letters, has on the date thereof been signed and subscribed by the
aforenamed testator in the presence of us who, at his express direction and in his
presence and in the presence of one another, have likewise signed our names jointly
with him upon each and every page thereof, and subscribed hereunder as witnesses
thereto and in attestation thereof.

AAA Sta. Ana, Manila
Witness Address

BBB Sta. Mesa, Manila
Witness Address

CCC San Juan City
Witness Address



NOTARIAL ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)
City of Manila ) S.S.


BEFORE ME, a Notary Public in City of Manila AAA personally appeared
before me with SSS ID. No. 12345 issued at Manila, on June 10, 2012, Known to
RIOFLORIDO, LEA ANGELICA R.
PRAC 1

me and by me known to be the same person who executed the
foregoing instrument and acknowledge before that the same is free and voluntary act
and deed.

Witness my hand and notarial seal on date and at the place first above
written.




ATTY. AAAAA
Commission No. 12344
Until December 2016
Office Address: Sta Ana, Mla.
IBP No. 1234/1-12-12
PTR No. 1234/1-12-12/Mla.
Roll No. 12202
MCLE No. 12010

Doc No. _____;
Page No. ____;
Book No. ____;
Series of 2014.


















RIOFLORIDO, LEA ANGELICA R.
PRAC 1


ATTESTATION CLAUSE OF J UDICIAL AFFIDAVIT


ATTESTATION

I hereby state, under oath, that I faithfully recorded the questions I asked and
the corresponding answers that the witness gave and that neither I nor any other
person present or assisting me has coached the witness regarding the latters
statement.

Sgd. ATTY. LEA RIOFLORIDO


SUBSCRIBED AND SWORN to before me this 30
th
day of August 2014 in the
city of Manila, affiant exhibiting to me his SSS ID No. 123456 issued at Manila on
October 2012.



ATTY. AAAAA
Commission No. 12344
Until December 2016
Office Address: Sta Ana, Mla.
IBP No. 1234/1-12-12
PTR No. 1234/1-12-12/Mla.
Roll No. 12202
MCLE No. 12010
Doc No. _____;
Page No. ____;
Book No. ____;
Series of 2014.