REPUBLIC OF THE PHILIPPINES}

DONE: IN THE CITY OF BAGUIO } S.S.

X =========================== X

AFFIDAVIT-COMPLAINT

I, AMADOR B. BULAN, of legal age, and a resident of #13

Sandawa Road, Baguio City, after having been sworn in accordance
with law hereby depose and say:

1. That I am the owner of a KB Chino Cargo Truck with plate no.

LOT 530
whichis primarily use in the regular business of general trucki
ng services, and the employer of ROLANDO SUIZO, the truck
driver and RENALDO KATIGBAK, the truck helper ;
2. That on October 26, 2017 while my driver Rolando was driving
back to our garage from a prior delivery in the South and
upon approaching the intersection of Sandawa Road and Mc
Arthur Highway along Matina Baguio City, the speeding bus
with body no. 1357 which we later knew was driven by
BENJAMIN V. BIGAT who resides at #26 Ecoland Subdivision,
smashed hit the left back portion of our truck bearing plate
no. LOT 530instantly killing our truck helper RENALDO
KATIGBAK, death certificate and the report of attending
physician, are hereto attached for reference;
3. That the said bus with body no. 1357 is owned by RABBIT BUS
LINES;
4. That BIGAT drove his vehicle at a very high speed and while
encroaching the opposite lane he did not bother to slacken or
reduce his speed or even stopped when it approached the
intersection;
5. That bystanders who were at the scene immediately tried to
rescue and give aid to our truck helper by bringing him to the
nearest hospital but he eventually passed away due to the
severity of his injury;
6. That BIGAT was violating the traffic rules when he encroached
the opposite lane and failed to stop or reduce his speed
considering that it was a cross thru road, and was driving the
bus recklessly when he smashed hit our truck;
7. That MARCELINO PADAYOG witnessed the incident and caused
the recording of the same at the proper police authorities, a
copy together with his affidavit of witness are hereto attached
for reference;
8. That I am executing this affidavit to attest to the truth of the
foregoing facts and to apprise the City Prosecutor of the
 same, for the purpose of prosecuting BENJAMIN V. BIGAT of
the crime of reckless imprudence resulting in homicide as
defined under the Revised Penal Code of the Philippines
as amended and the applicable special laws.

IN WITNESS WHEREOF, I have hereunto set my hands this 17 th day of

September 2018, at Baguio City, Philippines.

AMADOR BULAN
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio, this

17th day of September 2018.

ATTY. MAE ANN Y. BADUA

Investigating Prosecutor

CERTIFICATION

I hereby certify that I have personally examined the above named

affiant and that the foregoing statements were given by her voluntarily
and of her own free will and that she understood her affidavit.

ATTY. MAE ANN Y. BADUA

Investigating Prosecutor