Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

COMPLAINT

Plaintiff by the undersigned counsel and unto this Honorable court respectfully avers that:

1. Both Plaintiff and defendat are of age and is currently residing at 3 Rose st. Tondo Manila and 4 Rose St. Tondo Manila respectively;

2. Plaintiff is the owner of a certain personal property, namely a Hyundai Starex valued at P450,000 and more particularly described as follows to wit; A motor Vehicle namely a 4 cylinder 1999 Hyundai Starex van rented by the defendant on January 4 2012 to be used in defendants company outing. Which van defendant failed to return on the same day agreed upon by both parties.

3. Said property has not been distrained or taken for a tax assessment or seized under a writ of execution or preliminary attachment or custodia legis.

4. Plaintiff has demanded from defendant the return of said property but the later refuse and continues to refuse to do so.

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

WHEREFORE it is respectfully prayed that

1. The subject property be delivered to the plaintiff;

2. Defendant be made for the cost of this suit;

3. The plaintiff be granted such other reliefs consistent with law and equity;

City of Manila March 29, 2012.

(Sgd.) _____________________________

Counsel for Plaintiff

[Verification and Certification of non forum shopping]