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CITY OF PASAY ) S.S.
COMPLAINT FOR DAMAGES
3. That on January 14, 2019 about 11:40pm, at Narra Road, Brgy.
San Antonio, San Pedro City, Laguna, a yellow garbage truck
with plate number WML785 without headlights driven by
Antonio Ygono collided with a black motor vehicle with plate
number DC 15329 driven by Dharell Marcello Santelices and
Jazlen Ara Espino Brillantes, our daughter, as a back ride.
Herein attached as ANNEX “A” the sworn statement of Mario
Jacolbe Luarez Jr. who witnessed the incident, ANNEX “B”
the police report, ANNEX “C” Inquest Investigation and,
ANNEX “D” Joint Affidavit;
7. Since the total amount of P280,000.00 is not sufficient to cover
the medical expenses for the full recovery of JAZLEN ARA
ESPINO BRILLANTES, the plaintiffs requested ARTURO
PANGANIBAN the representative of the corporation for
additional financial support but it was ignored.
9. That the plaintiffs through counsel made a written demand to
Amalia Miranada Mallari, Arturo Panganiban Punzalan,
Danny Miranda and Pilotage Trading and Construction, Inc. to
comply with their legal obligation but it remain unanswered.
Herein attached as ANNEX “I” the final demand letter;
11. That plaintiffs, had suffered Actual damages for medicines,
laboratory examinations and hospital bills, in the sum of ONE
MILLION AND NINETY FOUR THOUNSAND FOUR
HUNDRED SISTY SIX PESOS AND FIFTY CENTOVOS
(P1,094,466.50).
12. That plaintiffs had suffered serious anxiety, sleepless nights,
and social humiliation for begging money just to survive the
daytoday expenditures. For that, the plaintiffs demand Moral
damages in the sum of THREE HUNDRED THOUSAND
PESOS (P300,000.00).
13. That to set as an example or correction of the public good
especially as the Corporation give services to the public, the
plaintiffs demand Exemplary damages in the sum of TWO
HUNDRED THOUSAND PESOS (200,000.00).
IN WITNESS WHEREOF, I have hereunto set my hand this 3 rd
day of July 2019, in the city of Pasay, Philippines.
________________
Affiant
SUBSCRIBED AND SWORN TO before me this 3rd day of July
2019 in Pasay City, Philippines. I hereby certify that I have personally
examined the affiant and I am satisfied that he fully understood and
voluntarily executed his complaintaffidavit.
Assistant City Prosecutor