Sunteți pe pagina 1din 5

Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
Branch ___
Davao City

Chong Go, Plaintiff,

CIVIL CASE No. _______________

- versus

FOR: Damages for death, Loss of


earning capacity, Moral damages
and Attorneys Fees.

Evil spirit, Defendant.


x- - - - - - - - - - - - - - - - x

COMPLAINT
COMES NOW, plaintiff, Chong Go, by counsel, and unto this
Honorable Court, most respectfully avers THAT:
1. Plaintiff is a Filipino, of legal age, married, and residing at Yumang
St., General Santos City, where he may be served with summons,
papers and other process of this Honorable Court HIGOT Law
Firm, Suite 704, Pardo Bldg., Bingka Street, Gensan City.
2. Plaintiff, upon going to the work, received a phone call from his wife
telling that she went away to another man. As a result of shock, he
ran over a restaurant and caused damages to the property as well
as injured three customers.
3. The plaintiff is hereby contends that the defendant is liable for the
damages he incurred.
4. The consecutive circumstances that happened to the plaintiff is at
the fault of the defendant, thereby, causing him to be anguished,
sued, and indemnified.

5. Hence, the petition seeks that the defendant be made liable to pay
for damages of restaurant and the of customers, in the amount
equivalent

to

FIVE

HUNDRED

THROUSAND

PESOS

(P

500,000.00).
6. Due to the sudden separation of his wife, he suffered mental
anguish and serious anxiety.
7. Consequently, Plaintiff was constrained to engage the services of
counsel to whom it obligated itself to pay as Attorney's Fees the
amount equivalent to TWENTY FIVE PERCENT (25%) of the total
amount to be adjudged in favor of plaintiffs, and the costs of this
suit.

PRAYER
WHEREFORE, the above premises considered, it is
respectfully prayed of this Honorable Court after hearing on the
merits, that:
a. Defendants be made liable to pay for damages for
death

in

the

amount

of

THREE

HUNDRED

THROUSAND PESOS.
b. Defendants be ordered to pay moral damages in the
amount of TWO HUNDRED THOUSAND PESOS (Php
200,000.00);
c. Defendants be ordered to pay attorneys fees in an
amount equivalent to TWENTY FIVE PERCENT (25%)
of the total amount to be adjudged in favor of plaintiffs;
d. Defendants be made liable for all the payments he
incurred to pay the costs of this suit.

Other reliefs just and equitable under the premises are


likewise prayed for.
For the Plaintiff
By
ATTY. BENITEZ BITOON
HIGOT Law Firm, Suite 704, Pardo Bldg.,
Bingka Street, Gensan City
PTR No. 1247838 1-20-2012 Davao City
IBP No. 911117 1-21-2012 Davao City
Roll No. 89994
MCLE Ex. No. 111-000748 1-13-2012
For 3rd compliance
ATTY. SANTO SANTILLAN
JIGO Law Firm, Hotel 704, Jumbo Bldg.,
Ilustre Street, Davao City
PTR No. 1367738 1-20-2013 Davao City
IBP No. 623417 1-21-2012 Davao City
Roll No. 8784
MCLE Ex. No. 221-102748 1-14-2013
ATTY. LEE GREY LARONA
KATI Law Firm, Suite 704, Pardo Bldg.,
Langka Street, Davao City
PTR No. 5747838 1-20-2012 Davao City
IBP No. 714117 1-21-2012 Davao City
Roll No. 69544
MCLE Ex. No. 341-000748 1-13-2012
ATTY. HALLEY MAO
PLAGI-FU Law Firm, Suite 704, Pardo Bldg.,
Choco Street, Davao City
PTR No. 7947838 1-20-2012 Davao City
IBP No. 397117 1-21-2012 Davao City
Roll No. 69992
MCLE Ex. No. 121-085748 1-13-2012

Republic of the Philippines )


Davao City
)s.s
x- - - - - - - - - - - - - - - - - - - - - - - -x
VERIFICATION AND CERTIFICATION AGAINST FORUMSHOPPING
I Tia Paeng, Filipino, of legal age, married and a resident of
residing at 32E Jacinto St., Davao City, after having been duly
sworn to in accordance with law depose and say, THAT:
That I am the Plaintiff in the above-entitled case; That I have
caused the preparation of the above Complaint and I have read the
same and knows the contents thereof; That the allegations
contained therein are true and correct of my own personal
knowledge.
IN WITNESS WHEREOF, I have hereunto set my hand this
23 day of January, 2012 at Davao City, Philippines.
rd

SUBSCRIBED AND SWORN to before me this 23rd day of


January, 2012, by Tia Paeng, who exhibited to me her Voters ID
No. 12345 issued at Davao City, Philippines on May 12, 2005.
WITNESS MY HAND AND SEAL.
Doc. No. 0012;
Page No. 003;
Book No. 001;
Series of 2012.

ACKNOWLEDGEMENT
Received from Tonying C. Lato, his Cimarron Jeepney
with Plate No. LXX-349, for repair and other necessary fixing.
The said acceptance is with the consequent assurance that
we will be responsible for any and all incidents which may
occur while the said vehicle is in our custody.
Done this 29th day of December, 2010.

Marco Lava
Owner and Manager
Ultra
Speed
Machine Shop
and As Metal Products

S-ar putea să vă placă și