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COMPLAINT
COMES NOW, Plaintiff Davao Rabbit Bus Line, Inc. and the
undersigned counsel unto this Honorable Court most respectfully files
this Complaint by averring THAT:
THE PARTIES
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Complaint
4. Defendant Rolando Suizo, Filipino, of legal age, married
and a resident of Guerrero Street, Davao City, Philippines, is an
employee of defendant Bulan and the driver of the KB Hino Cargo
Truck owned by the latter. Defendant Suizo may be served with
summons and other court processes in the said address.
CAUSE OF ACTION
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Complaint
13. On December 10, 2012, plaintiff, through counsel, sent a
demand letter addressed to defendant Bulan for the reimbursement
of the expenses incurred for the repair of the bus. (See attached
demand letter as Annex “D”)
PRAYER
MELCHORA AQUINO
General Manager
Assisted by
By
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Complaint
BENEDICT ONTAL
Roll No. 64337
PTR No. 249755; 01-03-13; D.C.
IBP Life Member Roll 890786
MCLE Compliance No. III-335512; 01-11-2012
Issued at Davao City
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Complaint
JURAT and CERTIFICATION
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Complaint
“ANNEX C”
OFFICIAL RECEIPT
NO. 14526
PARTICULARS AMOUNT
REPAIRS
Php 74,000.00
Labor 26,000.00
Remarks: PAID
Date of discharge: Dec. 9, 2012
Received Amount: Two Hundred Fifteen Thousand Pesos Only (Php100,000.00)
Mode of Payment: CASH
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Complaint
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Complaint