Professional Documents
Culture Documents
COMPLAINT
THE PARTIES
Page | 1
Complaint
CAUSE OF ACTION
Page | 2
Complaint
14. On April 13 2018, plaintiff, through counsel, sent a demand
letter addressed to defendant Metro Shuttle Bus and its President
Arellano, for the reimbursement of the medical and operation she
expenses incurred. (See attached demand letter as Annex “G”)
PRAYER
ii. Six Million and Two Four Hundred Thousand Pesos (Php
6,204,000) for loss of earning and income;
Page | 3
Complaint
iv. Fifty Thousand Pesos (Php50,000.00) for exemplary
damages; and
_
________________
BRIDGET ABAD
Plaintiff
Assisted by
A RAFOL
LAW and ACCOUNTING FIRM
11th Floor Royal Building Center,
KGC, Phil-Japan Friendship
Highway ,Catitipan,
Davao City, Philippines.
e-mail: arafolLAF@gmail.com
telephone number: 082-269-4321
By
MA. GLORIA TRINIDAD ARAFOL
Roll No. 65821
PTR No. 234567; 01-03-17 D.C.
IBP Life Member Roll 660786
MCLE Compliance No. III-335512; 01-11-2017
Issued at Davao City
Page | 4
Complaint
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING
BRIDGET ABAD
Affiant
SUBSCRIBED AND SWORN TO before me this 14TH day of July
2018 at Davao City, Philippines, affiant exhibited to me his current and
unexpired driver’s license numbered L03-15678 valid until May 1, 2019,
bearing his photograph and signature as competent proof of her
identity.
Page | 6
Complaint
“ANNEX B”
Vehicle # 1 Vehicle # 2
Type Passenger Bus Passenger bus
Plate No. ABC 123 CDE456
Name of Driver Zanjoe Marodo Coco Martin
Address Tagum City Davao City
Vehicle Owner Metro Shuttle Bus Bachelor Express Bus
Company Company
Address Tagum City Davao City
Damages Multiple
Prepared by:
SPO1 Diosdado Laurel
PO3 Joseph Marcos
Approved by:
Ferdinand Estrada
Police Superintendent
Acting Chief of Police
Page | 7
Complaint
“ANNEX C”
Doctor’s Fee Receipt
Page | 8
Complaint
“ANNEX D”
Hospital Bills
Page | 9
Complaint
“ANNEX E”
Medical Prescription
Page | 10
Complaint
ANNEX “F”
Pay slip
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
= 6,204,000
Page | 11
Complaint
ANNEX “G”
A RAFOL
LAW and ACCOUNTING FIRM
11th Floor Royal Building Center,
KGC, Phil-Japan Friendship
Highway ,Catitipan,
Davao City, Philippines.
e-mail: arafolLAF@gmail.com
telephone number: 082-269-4321
_______________________________________________________________________
Andrew Arellano
President
Metro Shuttle Bus Company
We are writing this letter in behalf of our client, Bridget Abad, on the matter
regarding the vehicular accident between your and our client’s respective vehicles to wit:
In view of the abovementioned accident, it became necessary for our client to engage
the services of mechanics and bus body works specialists to repair and restore the
passenger bus’ condition in order to be roadworthy again.
Consequently, our client demand of you the reimbursement of the incurred
expenses amounting to Two Million and One Hundred Thousand Pesos (Php 2,100,000.00)
which you may pay in cash or through our client’s account in BDO Unibank. (See attached
Official Receipt).
This serves our demand for you to settle the said amount within Fifteen (15) days
from receipt of this letter. Otherwise we will be constrained to file a necessary legal action
against you to protect the interest of our client.
We trust that you will give this matter your prompt and preferential attention to
avoid expense and inconvenience of litigation.
Page | 12
Complaint
“ANNEX H”
A RAFOL
LAW and ACCOUNTING FIRM
11th Floor Royal Building Center,
KGC, Phil-Japan Friendship
Highway ,Catitipan,
Davao City, Philippines.
e-mail: arafolLAF@gmail.com
telephone number: 082-269-4321
________________________________________________________________________
Andrew Arellano
President
Metro Shuttle Bus Company
We are writing this letter in behalf of our client, Bridget , on the matter regarding
the vehicular accident between your and our client’s respective vehicles to wit:
Page | 13
Complaint
“ANNEX I”
Page | 14
Complaint