REPUBLIC OF THE PHILIPPINES

6TH JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH ___
ILOILO CITY

LOVELY L. DE LA TORRE,
Plaintiff Special Civil Action
No.________________
FOR: INTERPLEADER
- versus -

JURY JASON B. JUNSAN and JOSEPH M. MABUNAY,

Defendants
x -----------------------x

COMPLAINT

Plaintiff, through the undersigned counsel unto this Honorable Court,

hereby respectfully avers:

1. That plaintiff is of legal age, Filipino, single, and a resident of Ungka

II, Pavia, Iloilo, Philippines;

2. That defendant JURY JASON B. JUNSAN is of legal age, Filipino,

single, and a resident of Zone 3, Bo. Obrero, Iloilo City where he may be
served with summons and other legal processes of the honorable court;

On the other hand, defendant JOSEPH M. MABUNAY is of legal age,

Filipino, single, and a resident of Zone 3, South San Jose, Molo, Iloilo City
where he may be served with summons and other legal processes of the
honorable court;

3. That on February 02, 2018, while waiting for her boarding schedule,
plaintiff found a Louis Monet Meteoris Collection watch without knowing
who its true owner is;

4. That the watch is now in plaintiff’s possession;

5. That on February 05, 2018, defendants made similar representations

to the plaintiff as to ownership of the watch;

6. That the plaintiff, who claims no interest in the watch, cannot

determine who between the defendants is the real owner and thus seeks to
compel defendants to interplead and litigate their several claim between
themselves.

WHEREFORE, it is respectfully prayed that this Honorable Court

issue an order directing defendants to interplead with one another to determine
their respective rights and claims and to allow plaintiff to recover his expenses
for safekeeping and the costs of this suit, as first lien upon the subject matter
of this action.

Other relief just and equitable under the premises are likewise rayed
for.

Iloilo City, February 12, 2018.

ATTY. ABUNDIO A. BACATAN

Bacatan Law Office, Don Bosco Boys’ Home,
Dumangas, Iloilo
Roll of Attorneys No. 30573
PTR NO. 2651863, 05/18/17, Iloilo City
IBP NO. 2123, 05/18/17, Iloilo City
REPUBLIC OF THE PHILIPPINES)
ILOILO CITY) SS.
x----------------------------x

VERIFICATION AND CERTIFICATION

I, LOVELY L. DE LA TORRE, of legal age, Filipino, married, and

a resident of Ungka II, Pavia, Iloilo, Philippines, after being sworn in
accordance with law, hereby depose and say:

(1) That I am the Plaintiff in the above-entitled case;

(2) That I have caused the preparation of the above Complaint and I
have read the same and understood the contents thereof;

(3) That the allegations contained therein are true and correct of my
own personal knowledge and based on authentic records.

(4) That I further certify that: I have not theretofore commenced any
other action or proceeding or filed any claim involving the same issues or
matter in any court, tribunal, or quasi-judicial agency and, to the best of my
knowledge, no such action or proceeding is pending therein; if I should
thereafter learn that the same or similar action or proceeding has been filed or
is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or quasi-judicial agency, I undertake to report such fact within five (5)
days therefrom to the court or agency wherein the original pleading and sworn
certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 12th

day of February, 2018 at Iloilo City, Philippines.

LOVELY L. DE LA TORRE
Affiant
TIN 98765-001; Iloilo City
 SUBSCRIBED AND SWORN to before me, this 12th day of
February, 2018 affiant exhibiting to me her Tax Identification Card as
shown above below her name as competent evidence of her identity.

ATTY. ABUNDIO A. BACATAN

Notary Public for and in the City and Province of Iloilo
My Commission No. is 93
Expires on December 31, 2019
Bacatan Law Office, Don Bosco Boys’
Home, Dumangas, Iloilo
Roll of Attorneys No. 30573
PTR NO. 2651863, 05/18/17, Iloilo City
IBP NO. 2123, 05/18/17, Iloilo City

Doc. No. 5;
Page No. 2;
Book No. 1;
Series of 2018;