Republic of the Philippines

Regional Trial Court

National Capital Judicial Region
Branch 39, Manila
Republic of the Philippines
}
____________________________

} S. S.

MICHELLE ANNE B. RECTO

Plaintiff,

Civil Case No.: 123456-A

For: Replevin

-versus-

HIMCHAN KIM
Defendant,

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

Replevin
Plaintiff through the undersigned counsel, and unto this Honorable Court, respectfully
avers that:
1. Both the plaintiff and the defendant are of age, and residents of Quezon City;

2. Plaintiff is the owner of a certain personal property, namely, an automobile: a

2008 Audi R8, valued at EIGHT HUNDRED THOUSAND PESOS (Php 800,000.00),
and more particularly described as follows, to wit:

That the automobile was only rented to the defendant herein, upon the premise that
weekly payments shall be made from the date that it was leased. The agreement
started on June 10, 2013 but after the first two weeks, payments have stopped and the
defendant has refused to return the property. That to this date, 10 th of September 2013,
the property has yet to be returned.

3. The said property has not been distrained or taken for a tax assessment or a fine
pursuant to law, or seized under a writ of execution or preliminary attachment, or
otherwise placed under custodial legis.

4. The plaintiff herein has demanded of the defendant the delivery of said property
but the latter refused and continues to refuse to do so; and

5. Plaintiff hereby executed a performance bond in double the value of the subject
property, in favor of the defendant, for the return of the property to the latter if such
return be adjudged and for the payment of such sum as the defendant may recover in
this action.

WHEREFORE, it is respectfully prayed:

(a) That the property in question be ordered delivered to the plaintiff;

(b) That defendant be made to pay the costs of this suit;
(c) And that plaintiff be granted such further relief consistent with law and
equity.

IN WITNESS WHEREOF, I have hereto have hereby set their hands on the 10 th day of
September 2013, in Quezon City, Metro Manila

________________________
Michelle Anne B. Recto

Conforme:

________________________
Atty. Yongguk Bang

Signed in the presence of:

__________________________
Zelo Choi

________________________
Daehyun Jung

ACKNOWLEDGEMENT

REPUBLIC OF THE PHILIPPINES}

CITY OF
QUEZON
} SS.
x-----------------------------------------------x
BEFORE ME, a Notary Public for and in Quezon City, Philippines, this 10th Day of
September, 2013, personally appeared the following persons exhibiting to me their
respective identifying instruments, to wit:
Name

Identifying Instrument

Michelle Anne B. Recto

TIN No: 672-098-267-000

known to me and to me known to be the same person/s who executed the foregoing
Replevin consisting of 5 pages including the page on which this Acknowledgment is
written, and who acknowledged to me that the same is their free and voluntary act and
deed.
WITNESS MY HAND AND SEAL this 10th Day of September, 2013, at Quezon City,
Philippines.

YOUNGBAE DONG
Notary Public
Attorneys Roll No.: 24315672
PTR No.: 85764 01/01/2010
IBP N. 5637658, 01/01/2010
MCLE Compliance No.: 9875
Quezon City, Philippines

Doc. No.: ________

Page No.: ________
Book No.:________
Series of 2012

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, MICHELLE ANNE B. RECTO, of legal age, after having been duly sworn in
accordance with law, depose and state that:
1. I am the defendant in the above-stated case;
2. I caused the preparation of the foregoing answer;
3. I have read the contents thereof and the facts stated therein are true and correct of my
personal knowledge and/or on the basis of copies of documents and records in my
possession;
4. I have not commenced any other action or proceeding involving the same issues in the
Supreme Court, the Court of Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action or proceeding is pending in
the Supreme Court, the Court of Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to this Honorable
Court.

________________
Affiant
SUBSCRIBED AND SWORN to before me this 10th day of July 2013, at the City
of Manila, affiant exhibiting to me his Community Tax Certificate No. 125256 issued on
September
10,
2013
at
the
City
of
Manila,
Philippines
Doc. No. ;________
Page No. ;________
Book No. ;________
Series of 2013.