REPUBLIC OF THE PHILIPPINES
6TH JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 30
ILOILO CITY
COMFORT RIDE CAR RENTALS Civil Case No. 99212
Plaintiff FOR: REPLEVIN
- versus -
FRANZISKA VON KARMA,
Defendant
X-------------------------------------X
COMPLAINT
Plaintiff by the undersigned attorney, and unto this Honorable Court,
respectfully avers that:
1. That Plaintiff is a domestic corporation existing under the laws of the
Philippines, with offices at 311 P. Del Rosario St., Molo, Iloilo City,
while defendant is a Filipino citizen, residing at House No. 1024,
Crown Regency Subdivisions, where he may be served with Summons;
2. That plaintiff is the registered owner of a motor vehicle described as
a Kia Carnival, model 2010, with Plate No. XFC-909;
3. That on December 05, 2017, defendant rented from plaintiff said Kia
Carnival car for a week from December 05 to 11, 2017;
4. That on December 12, 2017, and for the next four (4) days thereafter,
plaintiff demanded from defendant the return of the said car; but
defendant avoided returning the car by giving one reason or another;
5. That said car has not been taken for a tax assessment or fine pursuant
to law, or seized on execution or attached;
6. That the value of the said car is three hundred fifty thousand pesos;
7. That plaintiff is ready and willing to give bond executed to the
defendant in double the value of the property for the return of the
property to the defendant should defendant be adjudged, or for the
payment of such sum that defendant may recover from plaintiff in the
action.
Wherefore, plaintiff prays that:
1. The sheriff or other proper officer be ordered to take possession of
the car and dispose of it in accordance with the Rules of Court;
2. After hearing, judgment be rendered declaring that plaintiff is
entitled to the possession of the car or, should this prove unavailing,
sentencing defendant to pay the value of the car.
Iloilo City, January 30, 2018.
ATTY. JOSHUA JOHN A. GRANADA
NOTARY PUBLIC for Province of Iloilo
Commission Serial No. 157775
Until December 3, 2018
Granada and Javier Law Offices
Roll of Attorney 082557
IBP No. 312421/04/04/14/Iloilo City
PTR No. 397564/ Province of Iloilo
MCLE No. V-19022568
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF ILOILO ) SS.
x----------------------------x
VERIFICATION AND CERTIFICATION
I, COMFORT RIDE CAR RENTALS, acting through my duly
authorized agent JUNE ALLIENTO, after having been duly sworn in
accordance with law, depose and state that:
1. I am the petitioner in the above-stated case;
2. I caused the preparation of the foregoing petition;
3. I have read the contents thereof and the facts stated therein are true and
correct to my personal knowledge and/or on the basis of documents and
records in my possession;
4. I have not commenced any other action or proceeding involving the
same issue 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; and
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.
________________________________
COMFORT RIDE CAR RENTALS
Affiant
ACKNOWLEDGMENT
(Republic of the Philippines)
City of Iloilo) S.S.
SUBSCRIBED AND SWORN to before me, a Notary Public, for and
in the City of Iloilo, this 29th day of January 2018 personally appeared:
Name Identification Card Issued On/At
June Alliento TIN ID Iloilo City, 03/20/16
all known to me to be the same person who executed the foregoing instrument
and hereby acknowledged to me that the same is their free and voluntary act
and deed.
This instrument consisting of four (4) pages, including this page on
which this acknowledgment is written refers to a REPLEVIN and has been
signed by the party and sealed with my notarial seal.
WITNESS MY HAND AND NOTARIAL SEAL.
Doc. No.____; ATTY. JOSHUA JOHN A. GRANADA
Page No.____; NOTARY PUBLIC for Province of Iloilo
Book No.____; Commission Serial No. 157775
Series of 20___. Until December 3, 2018
Granada and Javier Law Offices
Roll of Attorney 082557
IBP No. 312421/04/04/14/Iloilo City
PTR No. 397564/ Province of Iloilo
MCLE No. V-19022568
