Professional Documents
Culture Documents
COMPLAINT
COMES NOW, plaintiff __________________, by counsel, and unto this
Honorable Court, most respectfully avers THAT:
2. That defendant 2GO Shipping Lines is the owner of M/V Saint Thomas
Aquinas, duly organized under the Philippines law, engaged in the doing business
as a passenger vessel, wherein its principal place of business is located at
________________ where it may be served summons; while M/V Sulpicio Express
Siete (same with 2GO format);
4. That due to the negligence of the defendants, the vessels collided and
sank, which resulted to the death of many passengers including plaintiff’s daughter;
5. That by reason thereof, the plaintiff ______ suffered not only physical
injuries for which she was medically treated but also mental anguish, serious
anxiety, and moral shock;
Other reliefs just and equitable under the premises are likewise prayed for.
___________(Signature)_________
Name of Plaintiff
Plaintiff
Assisted by:
By:
______________________________
(NAME OF ATTORNEY FOR PLAINTIFF)
Public Attorney II
IBP No. AR001147/01-08-18/Q.C.
Roll No. 59364
MCLE Compliance No. V-0005461 Jan. 13, 2015
Copy Furnish
DE BORJA LAMORENA & DUANO LAW OFFICES
Counsel for Defendant
Unit 2502-A East Tower, Philippine Stock Exchange Center,
Exchange Road, Ortigas Center, Pasig City
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING
I, _______________________, of legal age, single/married after having been duly
sworn in accordance with law, depose and state that:
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of
documents and records in my possession;
4. I have not commenced any other action or proceeding involving the same
issues in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;
5. To the best of my knowledge and belief, no such action or proceeding is
pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;
6. If I should thereafter learn that a similar action or proceeding has been filed
or is pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this Honorable Court.
___________________________
Affiant