COMPLAINT

Plaintiff, by counsel, respectfully alleges:

1. That both the plaintiff and the defendant are of age and residents of ______________;
2. That said plaintiff is the lawful owner of a personal property, namely, _____________, valued at
_____________ and more particularly described as follows:
(description of property)
3. That on or about the ____ day of _____, herein defendant borrowed said property from Plaintiff
promising to return the same the next day;
4. That on _____, 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 same belongs to him;
5. That plaintiff, in accordance with the Rules of Court, hereby applies for an order for the delivery of
said ________________- 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 _________.
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.
________ City, Philippines, this _____ day of _______2015.

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

VERIFICATION with CERTIFICATION OF NON-FORUM SHOPPING