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DEPARTMENT OF JUSTICE
OFFICE OF THE PROSECUTOR
ALBAY
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.
COMPLAINANT