Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 95
Manila City

Cris Medina Civil Case No. 81181

Plaintiff, FOR: COLLECTION OF
SUM OF MONEY WITH
-versus- APPLICATION FOR WRIT
OF PRELIMINARY
Judd Valderrama ATTACHMENT
Defendant.
X--------------------------------------------------------------------X

Complaint with Prayer for Preliminary Attachment

Plaintiff thru counsel, and unto this Honorable Court,

respectfully avers that:

1. Both the plaintiff and defendant are of age and residents

of Manila City.

2. That defendant herein owes the plaintiff the amount of

ONE HUNDRED TWENTY THOUSAND PESOS (Php
120,000.00) stemming from a sale transaction entered by
parties for the sale of a second hand car.

3. That the defendant had refused to pay the sum despite

timely and consistent demand of the plaintiff.

4. That the court, in an earlier case decided in July 20, 2018

has already adjudged the plaintiff deserving of the amount
prayed herein.

Allegations for the Issuance of for Preliminary

Attachment

Plaintiff further states and alleges:

5. Plaintiff has a valid and sufficient cause of action against

the herein defendant regarding the collection of sum of
money which is already due and demandable;

6. Defendant has removed or disposed of or is about to

remove or dispose of his property, with intent to defraud
his creditors;
 7. The amount due to the plaintiff is as much as the sum for
which an order of attachment is sought to be granted, the
defendant’s 2007 Nissan Serena, above all legal
counterclaims on the part of the defendant;

8. That the defendant does not have sufficient security for

the claim sought for the plaintiff against him;

9. Plaintiff is willing to put up a bond for the issuance of a

preliminary attachment in an amount fixed by the court,
not exceeding the sum of ONE HUNDRED TWENTY
THOUSAND PESOS (Php 120,000.00) equal to the amount
of the plaintiff’s claim, upon the condition that the plaintiff
will pay the costs that may be adjudged to the defendant
and all damages which he may sustain by reason of the
attachment if this Court so adjudge that the plaintiff was
not entitled thereto.

PRAYER

WHEREFORE, it is respectfully prayed that:

1. Pending the hearing of this case, a writ of preliminary

attachment be issued against the property of the
defendant to serve as security for the satisfaction of any
judgment that may be recovered herein; and

2. After due hearing on the principal cause of this action,

judgment be rendered against the defendant for the sum
of Php 120,000.00 with interest as may be awarded by the
court from the time the litigation had started, plus costs of
this suit.

Other reliefs just and equitable are likewise prayed for.

IN WITNESS WHEREOF, I have hereto have hereby set their

hands on the 18th day of November 2018, in Manila City, Metro
Manila

______________________________
Mara Clara Castro
IBP No. 453579-5/23/15
PTR No. 6607415-5/23/15
 CERTIFICATION OF NON-FORUM SHOPPING

I, Cris Medina, of legal age, after having been duly sworn in

accordance with law, depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated

therein are true and correct of my personal knowledge
and/or on the basis of copies of documents and records in
my possession;

4. I have not commenced any other action or proceeding

involving the same issues in the Supreme Court, the Court
of Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

6. If I should thereafter learn that 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 undertake to report that fact within five (5)
days therefrom to this Honorable Court.

______________________________
Cris Medina
Affiant
REPUBLIC OF THE PHILIPPINES)
CITY OF MANILA ) S.S.

AFFIDAVIT FOR PRELIMINARY ATTACHMENT

I, CRIS MEDINA, Filipino, of legal age, single, residing at 159

Malvar St, Manila City, after being sworn to in accordance with
law, deposes and say:

1. That I am the plaintiff above-entitled case;

2. That a sufficient cause of actions exists against the

defendant named therein;

3. That this action is one of those specifically mentioned in

Sec. 1 of Rule 57 of the Rules of Court, whereby a writ of
preliminary attachment may lawfully issue, namely:
“in an action against a party who has removed or
deposed of his property, or is about to do so, with
intent to defraud his creditors;”

4. That there is no sufficient security for the claim sought to

be enforced by the present action;

5. That the amount due to the plaintiff in the above-entitled

case is as much as the sum for which an order of
attachment is proper.

IN WITNESS WHEREOF, I have hereto have hereby set their

hands on the 18th day of November 2018, in Manila City, Metro
Manila

______________________________
Cris Medina
Affiant

SUBSCRIBED AND SWORN to before me this 18th day of

November 2018, in Manila City, Metro Manila, affiant having
exhibited to me his License No. 3790682 issued until July 29,
2022.

Doc. No. : ________;

Page No. : ________;
Book No. : ________;
Series of 2018.