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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROSECUTOR
ALBAY

THE PEOPLE OF THE PHILIPPINES


Complainant,

COMPLAINT- AFFIDAVIT

I, Mr. Z, of legal age, single, Filipino and a resident of Brgy. 3, Tabaco City, after
being sworn in accordance with the law, depose and state that:

1) Sometime in the morning of February 14, 2016 along Rizal Street, Legazpi
City, Mr Y, to be hereinafter referred to as the accused, being then the driver
of a passenger jeepney vehicle who willfully, unlawfully and feloniously
drove the same in a reckless, careless, negligent and imprudent manner
without taking any precaution to avoid damage to property and injuries to
person, causing such grave negligence and imprudence the said vehicle to
collide with another passenger jeepney driven by Mr. X, in which I was a
passenger. Thereby causing me serious physical injuries on the different
parts of my body.

2) Due to the strong impact of the collision, the bone on my left leg and on my
right arm were fractured and I also lost my left eye. These serious bodily
injuries required stern medical attendance for a period of two months at
Bicol Regional Training and Teaching Hospital in Legazpi City and incurred
the total amount of Php 150, 000.00 as my hospitalization expense. Further,
due to my inability to work because of the injuries I sustained entailed in the
incident, I also lost Php 1,000.00 per day for the period of three months from
my gainful employment.

3) The investigation conducted by PNP Legazpi clearly establishes the


recklessness of the accused. As contained in the report provided by PNP, the
jeepney in which I was a passenger thereof driven by Mr. Z was traversing
the route of Legazp- Daraga and when we reached Rizal Street as described
above, Mr. X, unintentionally lost his break. While damage to property and
injuries to persons may be avoided with Mr. Z’ loss of his break, Mr. Y
came, running at a very high speed on the highway while overtaking another
vehicle causing the collision stated above.

4) Therefore, the accused’s overtaking and the speed in which he drove


primarily caused the collision of vehicles. Being the a driver, it is expected
that he practice the necessary diligence and precaution and with him failing
to do so, he should be made liable for the injuries I’ve sustained as well as
all the expenses for my hospitalization and the amount representing my lost
from my gainful employment during my recovery period.
5) I am therefore executing this Complaint- Affidavit in support of the charges
for Reckless Imprudence Resulting in Serious Physical Injuries against the
accused.

IN WITNESS WHEREOF, I have hereundo set my hand this January 18,


2017 at Legazpi City, Philippines.

COMPLAINANT

SUBSCRIBED AND SWORN to before me this January 18, 2017 at


Legazpi City, Philippines. I hereby certify that I have examined the Affiant and
that I am fully satisfied that he has voluntarily executed and understood the
contents of his Complaint- Affidavit.

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