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Regional Trial Court
Branch 29, Toledo, Cebu city

Jerry Latorre,

-versus- Civil Case No. 0002

For Replevin

ABC Corporation,
Represented by Maleficent Beauty


Plaintiff, by counsel, respectfully alleges:

1. That both the plaintiff and the defendant are of age and residents of Toledo City and Cebu
City respectively;

2. That said plaintiff is the lawful owner of a personal property, namely, three motorcyles,
valued at P180,000.00 and more particularly described as follows:

(description of property)

3. That on or about the 1st day of April 2007, herein defendant borrowed said property from
Plaintiff promising to return the same the next day;

4. That on April 12, 2007, and for ten (10) days thereafter, the herein Plaintiff demanded for
the return of the said property but despite repeated demands, said Defendant refused and still
refuses the said property claiming that the former ever owed the latter more than the value of
the three motorcycles;

5. That plaintiff, in accordance with the Rules of Court, hereby applies for an order for
the delivery of said three motorcycles- and hereby files the necessary affidavit and bond
hereto attached, as Annex A and Annex B, respectively, and made integral parts of this
application and complaint;

6. That the herein plaintiff is ready and willing to file a bond, executed to the defendant in
double the value of the property stated above, for the return of the property to the Defendant if
the return thereof be adjudged and for the payment to the Defendant of such sum as he may
recover from the Plaintiff in the action.

WHEREFORE, it is respectfully prayed:

1. That the property in question be ordered delivered to the plaintiff or if material delivery be
not possible, that defendant be ordered to pay the plaintiff its actual value, namely the sum
of P180,000.00.

2. That the defendant be made to pay the costs of this suit, and plaintiff be granted such other
equitable relief consistent with law and equity.
Toledo City, Philippines, this 26th day of June 2007.

Name ____________________________
Office Address ____________________
Roll of Attorney No. ________________
PTR No.___, ___ (date and place of issue)
IBP No. ____, ___ (date of issue) (chapter)


I, Jerry Latorre, of legal age, after having been duly sworn in accordance with law,
depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

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

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



SUBSCRIBED AND SWORN to before me this 26 th day of June 2007 at Toledo

City affiant exhibiting to me his Community Tax Certificate No. 15-3129-213 issued on
June 1, 2007 at Toledo City.

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