REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
MANILA

LILIT BARGE TRANSPORT SERVICE

represented by GENEROSA CUSAP and
ANGELO M. CUSAP I.S No. ________________
Complainant

- versus –

BAUER, INC. represented by ____________

CADCOR, INC. represented by __________
__________
x-----------------------------------------------------------x
I, Generosa M. Cusap ; of legal age, widow, Filipino and a
resident of 3445 San Roque Street, Sta. Ana, Manila, after having duly sworn
according to law hereby depose and say:
1. I am one of the co-owner of LILIT BARGE TRANSPORT SERVICE a
business duly recognized and registered under the Philippine laws and with
an office address at 543 New Panaderos Street, Sta. Ana, Manila, Brgy. 893,
Zone 93 (“Lilit Barge”)

2. Lilit Barge is engaged in a business in transporting passengers through

a Non-Propelled Mini-Barge/ Banca from Mandaluyong Market Port to
Makisig St., Bacood Sta. Mesa Manila.

A copy of Business Permit for the year 2018 and Department of Trade and
Industry Certificate is attached herein as Annex “A” and “B”

3. Bauer, Inc – A Corporation duly recognized and authorized by law

and with an office address at 2F Regalia Park Tower A. 150 P. Tuazon St.
Cubao, Quezon City
4. Cadcor Inc – A Corporation duly recognized and authorized by law
and with an office address at

5. Sometime between 12:10 a.m and 1:00 a.m, on or about 13 June 2018,
our Non-Propelled Mini Barge was damaged and bumped by a Tag Boat
while it is docked in our Main Port in Mandaluyong Market, which cost
damage to former.

A photograph of the damage to the Mini Barge is attached as Annex “C”

6. Sometime on 20 June 2018, we filed a blotter in Barangay 893 regarding

the said Incident.

A photocopy of complaint filed with Barangay 893 is attached as Annex “D”

7. According to some bystander and several tenants in Mandaluyong

Market, it is a Tag Boat who bumped and caused damage to our Mini Barge
and such Tag Boat is registered under Bauer, Inc. and Cadcor, Inc. It was
driven by their employees, namely ____________________ and
___________________.

8. On 26 June 2018, a meeting was called by Chairman Boy Tuazon, who

is the elected and incumbent chairman of Barangay 893. I, together with my
son, Angelo Cusap and Ms. Regina Garcia who is also a part owner of Lilit
Barge. For the Respondent, Bauer, Inc. were represented by Atty. Charisma
V. Lopez and Mr. Nissan Leyson while on Cadcor, Inc. was represented by
Mr. Ian Mamuric.

A photocopy of the minutes of meeting is attached as Annex “E”

9. The Respondents admitted during the said meeting that they are the
one who committed the damages on the Mini Barge that we owned and
both parties agreed that for the fulfillment of this damage, respondents will
settle and pay an amount of SEVENTY THREE THOUSAND THREE
HUNDRED EIGHTY PESOS (PHP 73,380.00) for the damages we suffered
due to the horrible incident.
10. On __ ________ 2018, we demanded payment to the Respondents
regarding our agreed amounts based on the damages we incurred.
However, such demands failed to materialize. Several demands has been
made thru text messages and call but up to present, the Respondents failed
to settle their obligation to us.

A copy of Demand letter we issued to Bauer, Inc. and Cadcor, Inc. is

attached as Annex “F” and the stamp of received to show proof that the
demand letter received by the Respondents is attached as Annex “F-1”

11. The Complainant provide the payment for the necessary expenses for
the repair the damage caused by the negligent act of the Respondents.

A copy of the receipts for the necessary expenses of the Mini Barge is
attached as Annex “_”, “_”, “_”

12. I am executing this affidavit to attest to the truth of the foregoing facts
and for the purpose of charging Respondents, ________________ employed
under Bauer, Inc. and _____________________ employed under Cadcor, Inc.
with Reckless Imprudence resulting to damage to property under the
Revised Penal Code and any other appropriate charges.

GENEROSA M. CUSAP
Affiant

SUBSCRIBED AND SWORN to before me this __ day of ________________

2018 in Manila City.

ASSISTANT CITY PROSECUTOR

 CERTIFICATION
I hereby certify that I have examined the affiant and that I am satisfied
that he voluntarily executed and understood his Affidavit.

ASSISTANT CITY PROSECUTOR