1. TOUR-JACK Rent-A-Car, Inc. filed a complaint against Jetzon T. Lee for replevin in the Regional Trial Court. TOUR-JACK alleges that it owns a 1984 Mitsubishi Lancer that it rented to Lee from August 11-18, 2014 but Lee has failed to return the vehicle despite demands to do so.
2. TOUR-JACK requests that the sheriff take possession of the vehicle and dispose of it according to the rules of court. Alternatively, TOUR-JACK requests a judgment declaring it is entitled to possession of the vehicle or requiring Lee to pay its 290,000 peso value if possession cannot be granted.
3. The complaint
1. TOUR-JACK Rent-A-Car, Inc. filed a complaint against Jetzon T. Lee for replevin in the Regional Trial Court. TOUR-JACK alleges that it owns a 1984 Mitsubishi Lancer that it rented to Lee from August 11-18, 2014 but Lee has failed to return the vehicle despite demands to do so.
2. TOUR-JACK requests that the sheriff take possession of the vehicle and dispose of it according to the rules of court. Alternatively, TOUR-JACK requests a judgment declaring it is entitled to possession of the vehicle or requiring Lee to pay its 290,000 peso value if possession cannot be granted.
3. The complaint
1. TOUR-JACK Rent-A-Car, Inc. filed a complaint against Jetzon T. Lee for replevin in the Regional Trial Court. TOUR-JACK alleges that it owns a 1984 Mitsubishi Lancer that it rented to Lee from August 11-18, 2014 but Lee has failed to return the vehicle despite demands to do so.
2. TOUR-JACK requests that the sheriff take possession of the vehicle and dispose of it according to the rules of court. Alternatively, TOUR-JACK requests a judgment declaring it is entitled to possession of the vehicle or requiring Lee to pay its 290,000 peso value if possession cannot be granted.
3. The complaint
1. TOUR-JACK Rent-A-Car, Inc. filed a complaint against Jetzon T. Lee for replevin in the Regional Trial Court. TOUR-JACK alleges that it owns a 1984 Mitsubishi Lancer that it rented to Lee from August 11-18, 2014 but Lee has failed to return the vehicle despite demands to do so.
2. TOUR-JACK requests that the sheriff take possession of the vehicle and dispose of it according to the rules of court. Alternatively, TOUR-JACK requests a judgment declaring it is entitled to possession of the vehicle or requiring Lee to pay its 290,000 peso value if possession cannot be granted.
3. The complaint
Jetzon T. Lee, For: Replevin Defendant. x--------------------------------x
COMPLAINT
COMES NOW, the Plaintiff, through the undersigned counsel, and to this Honorable Court alleges:
1. That Plaintiff is a domestic corporation existing under the laws of the Philippines, at Enage Stree, Maasin City, while defendant is an Chinese citizen, residing at Room 6, Southern Comfort Hotel, Maasin City where he may be served with Summons;
2. That plaintiff is the registered owner of a motor vehicle described as a Mitsubishi Lancer, model 1984, with Plate No. DAY- 203;
3. That on August 11, 2014, defendant rented from plaintiff said Lancer car for a week from August 11 to 18, 2014;
4. That on August 20, 2014, and for the next three (3) 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 P290,000;
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 be adjudged, or for the payment of such sum that defendant may recover from plaintiff in the action.
2
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.
Maasin City, September 3, 2014.
JERRY W. TONGZON Counsel for the Petitioner PTR No. XXXXXX, , Hilongos, Leyte Lifetime Member No. XXXXX, 2018, Roll of Attorneys No. XXXX, TIN: MCLE Compliance NO. III 000000,