REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region

REGIONAL TRIAL COURT
BRANCH 101, Makati City

KPL RENT-A-CAR INC., herein

represented by Bobby Sakinyan;
Plaintiff,

-versus- Civil Case No._____________

For: Replevin

MANNY YABANG
Defendant.
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COMPLAINT

PLAINTIFFS, through counsel, to this Honorable Court most respectfully state:

1. Plaintiff is the general manager of KPL RENT-A-CAR INC. with office at Las
Pinas City; defendant is a Filipino resident, temporarily residing at Heritage Hotel, Roxas
Boulevard, Manila.

2. KPL RENT-A-CAR INC is a registered owner of a Honda CRV with license plate
number XXY 12344, which defendant, on 5 April 2018, rented from plaintiff for a period of one
(1) month.

3. On 5 May 2018, plaintiff demanded from defendant the return of the car but
defendant failed and refused to do so.

4. The car has not been taken for a tax assessment or a fine pursuant to law
nor has it been seized on execution or attachment. It’s present value is approximately One
Million Pesos (Php1,000,000.00)

5. Plaintiff is ready, willing and able to give bond in defendant’s name in

double the value of the property for the return of the property to defendant should that be
adjudged or for the payment of such sum that defendant may recover from plaintiff in this
action.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable

Court that judgment be rendered that the writ of replevin issue directing the Sheriff or any
other authorized officer to take possession of the car and dispose of it in accordance with the
Rules of Court and, after hearing, judgment be rendered declaring plaintiff to be the lawfully
entitled to the possession of the car and sentencing defendant to pay its value.
Other relief and remedies just and equitable under the premises are likewise prayed for

23 June 2018, Makati, Philippines.

RLSPC LAW OFFICES

Counsel for Plaintiff KPL RENT-A-CAR INC
UGF, Worldwide Corporate Center, Shaw
 2

Boulevard, Mandaluyong City

PLUS:
1. Verification and Certification against Forum Shopping