Republic of the Philippines NATIONAL CAPITAL JUDICIAL REGION METROPOLITAN TRIAL COURT MAKATI CITY Branch 031

JUANA SANTOS plaintiff CIVIL CASE NO: 2345 replevin -versusJULIANA MANGAPIT defendant COMPLAINT FOR RECOVERY OF PERSONAL PROPERTY (Replevin)

(CAPTION AND TITLE) COMES NOW, the Plaintiff, through the undersigned counsel in the above entitled case and to this Honorable Court alleges: 1. That said plaintiff is the lawful owner of the following described personal property; That on or about the 1st day of March 1988, herein defendant borrowed said property from Plaintiff promising to return the same the next day; That on April 1, 1988, and for 10 days thereafter, the herein Plaintiff demanded for the return of the said property but despite repeated demands, said Defendant refused and still refuses to return the said property claiming that the same belongs to him; That said property has not been taken from the said plaintiff for tax assessment or fine pursuant to law, or seized under an execution, or attachment against the property of the Plaintiff (or if so seized, that it is exempted from such seizure); That the actual value of the said personal property is P10, 000.00; 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

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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 auction. WHEREFORE, Plaintiff prays for judgment: 1. Ordering the sheriff or other officer of the Court forthwith to take such property into his custody and to dispose of it in accordance with the Rules of Court; 2. After trial of the issues, adjudging that the Plaintiff has the right to the possession of said personal property and rendering judgment in the alternative against the Defendant for the delivery thereof to the Plaintiff of the value thereof in case delivery cannot be made; 3. Ordering the defendant to pay the costs of this suit, and for such other equitable relief in the premises.

_________________________ Counsel VERIFICATION & CERTIFICATION ON NON-FORUM SHOPPING JURAT