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JONATHAN LINGAT Y. ALCAZAR, x-----------------------------------------------x REPLY AFFIDAVIT (Re: Counter Affidavit dated 26th April 2012) For: XV-03-INV-12b-0995
I, RICARDO T. LABRADO, of legal age, single and residing at No.111 Baesa Road, Caloocan City, after being duly sworn in accordance with law, hereby depose and state that;
counter-affidavit considering that his alleged version is completely inaccurate, misleading and a complete distortion of the facts;
2. The basis of the respondent in alleging that I was reckless are photographs of the
on its right side. Such position of the said vehicle would obviously be a result of respondent's car hitting my vehicle violently rendering it trapped in the side gutter;
5. It is also futile to raise the argument that I don't have the "right of way" and violated
traffic rules. No official report or finding of that fact was ever produced in the course of this proceeding to support this allegation. It is only base on the opinion of the respondent who has not establish his due competence and expertise in determining accident liabilities;
6. Moreover the respondent even admitted his liability on the said accident by bringing
supposition. His allegations of injury and damage are, at the very least absurd, if not outrageous, considering that the complainant are the ones whose legal rights are being impinged upon by the actions of complainants;
IN WITNESS WHEREOF, I have hereunto set my hand this_______________ at Quezon City, National Capital Region, Philippines.
RICARDO T. LABRADO
SUBSCRIBED AND SWORN to before me, this ____th day of _________, 2012, in, Quezon City, National Capital Region.
HONORABLE PROSECUTOR