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1 MUNICIPAL TRIAL COURT
11th Judicial Region
City of Digos
LUOD KHA,
Accused,
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Complaint
The undersigned, Ayaw Kho, accuses Luod Kha of the crime of Acts
Than on or about April 15, 2017, at about 9pm, in the City of Digos,
Province of Davao del Sur and within the jurisdiction of this Honorable
Court, the said accused Luod Kha did then and there willfully, unlawfully,
and feloniously embraced the undersigned, when the latter was about to
enter the comfort room of the hospital, holding her breasts and taking
liberties upon her person by force and against the will of the undersigned.
Contrary to law.
Witnesses
SERAFIN CHRISTENSEN,
Plaintiff,
Civil Case No. 12345
Vs Replevin
JOHN DOE,
Defendant,
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COMPLAINT
respectfully alleges:
organized and existing under Philippine laws with principal office at 311P.
Casal St., Quiapo, Manila, Philippines. For purposes of this action, plaintiff
may be served with all orders, notices and other processes through the office
without any legal or justifiable cause. A copy of the said demand letter
was constrained to institute the instant action and secure the services of the
vehicle described above, which Defendants are wrongfully detaining for the
7. That the property has not been distrained or taken for a tax
is P1,090,000.00;
bond of double the actual market value of the above-described motor vehicle
adjudged, and for payment of such sum as they may recover from the
PRAYER
with all its accessories and equipments, together with the Registration
Certificate thereof, with authority to break open and enter any premises
where the same may be found and to direct the manual delivery thereof to
the plaintiff in accordance with law, and after due hearing, to confirm the
b) Or, in the event that manual delivery of the said motor vehicle
Defendants, ordering them to pay plaintiff jointly and severally the principal
paid;
c) In either case, to order Defendants to pay Plaintiff t 10%
percent of the total amount due as Attorney's Fees, and to reimburse plaintiff
proved during trial, and other expenses incurred in the seizure of the said
Other relief as may be deemed just and equitable in the premises are
VERIFICATION / CERTIFICATION
AND AFFIDAVIT OF MERIT
I, Serafin Christensen, of legal age, Filipino, single, and a resident of
taken for a tax assessment or a fine pursuant to law, or seized under a writ of
execution or preliminary attachment, or otherwise placed under
good and sufficient bond of double the actual market value of said motor
adjudged, and for payment of such sum as they may recover from the
Complaint; that I have read the allegations contained therein and I know the
contents thereof. The allegations contained herein are true and correct based
same matter in the Supreme Court, the Court of Appeals, or any other
other tribunal or agency; and (c) if 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 and the corporation undertake to report such fact
within five (5) days therefrom to the court or agency wherein the original
Serafin Christensen
AFFIANT
Book No.12345;
Series of 2017.