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Republic of the Philippines )


Province of Nueva Ecija ) S. S.


COMPLAINT-AFFIDAVIT


I, RONALDO SANTOS y PUNZALAN, Filipino, of legal age, and presently
residing in Barangay Calasag, San Ildefonso, Bulacan, after having duly sworn
to in accordance with law, hereby depose and say:

1. That, on or about five oclock and twenty minutes in the afternoon
(5:20 p.m.), I am driving a white L300 Mitsubishi with plate RNF 479 along
Tarlac-Sta.Rosa road, vicinity of barangay Sta. Rosa Young, Zaragoza, Nueva
Ecija, transversing towards east direction bound to Zaragoza town proper;

2. That, the said L300 Mitsubishi was registered under the name of
Reynald Darryl G. Santos of barangay Calasag, San Ildefonso, Bulacan as can
be seen on the attached Official Receipt/Certificate of Registration (Annex A);

3. That, I am a holder of a Professional Drivers License (Annex B)
with number CO7-90-056285 which will expire on July 22, 2016, and which is
valid and existing during the date and time material to this case;

4. That, the said L300 Mitsubishi was involved in a Traffic Vehicular
Accident as per Police Report (Annex C) prepared by PO1 Denver M. Diaz on
March 30, 2014, as vehicular 2 (V2) and involving two (2) other vehicles;

5. That, on that date and time material to this case, I was driving a
white L300 Mitsubishi with plate RNF 479, at a speed of twenty (20) to twenty
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five (25) kilometers per hour (kph), maintaining a four (4) to five (5) meters
away from the vehicle in my front;

6. That, as I was looking at the vehicle in front of me, I noticed that
the said vehicle suddenly stopped, which in that case, I immediately stepped
on my break;

7. That, I felt a sudden motion that struck on the back portion of the
L300 Mitsubishi that I am driving;

8. That, however hard I stepped on the break, the rear front of the
vehicle which I was driving hit the rear back portion of the vehicle in my front
due to the force brought by the impact of the collision that hits the rear back of
the vehicle that I was driving;

9. Attached as Annex D-1&2 are pictures which shows that there is
indeed three (3) vehicles involved in this traffic vehicular accident, which are
the blue Nissan urvan, white L300 Mitsubishi and silver gray Kia Picanto;

10. Annex E-1&2 are also pictures which shows that the front portion
of the L300 Mitsuishi with plate RNF 479 hits the back portion of the Nissan
Urvan with plate CST 221, which incurred an estimated amount of sixty four
thousand two hundred pesos (P64,200.00) (Annex F), which is now a basis why
I am a respondent in NPS No.: III-09-INV-14D-00943 for RECKLESS
IMPRUDENCE RESULTING IN DAMAGE TO PROPERTY (Annex G);

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11. That, due to the said vehicular accident, the L300 Mitsubishi that I
drove incurred damage with an estimate of fifty thousand two hundred eighty
four and 24/100 pesos (P50,284.24) (Annex H);

12. That, the resulting damage to the Nissan Urvan driven by Mr.
Rommel Macaburas y Alberto and to the L300 Mitsubishi which I drove are all
attributable to the negligence of the third vehicle which is the Kia Piacanto with
plate RMM 786 driven by Errol Enriquez II y Mandap;

13. That, the proximate cause of the collision is the reckless driving of
the Kia Picanto driver in the name of Erro Enriquez II y Mandap which causes
the damage to the L300 Mitsubishi that I drove and which causes further
damage to the Nissan Urvan with plate CST 221;

14. Annex 9-A&B are pictures which shows that the Kia Picanto hits
the back portion of the L300 Mitsubishi which in turn causes the latter vehicle
to bump the Nissan Urvan which was situated in front;

15. That, the L300 Mitsubishi would not have hit the back porion of
the Nissan Urvan if not for the force of impact coming for the bumping of the
Kia Picanto at the back of the L300 Mitsubishi;

16. That, I am executing this affidavit to attest to the truth of the
foregoing and for filing a complaint against MR. ERROL ENRIQUEZ II y
MANDAP for RECKLESS IMPRUDENCE RESULTING IN DAMAGE TO
PROPERTY;


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IN WITNESS WHEREOF, I have hereunto affixed my signature this 6
th

day of May, 2014, in Cabanatuan City, Nueva Ecija.

RONALDO SANTOS
Affiant

SUBSCRIBED and SWORN to before me this 6
th
day of May, 2014, in
Cabanatuan City, Nueva Ecija. I hereby certify that I have personally examined
the above-named affiant and that I am satisfied that the foregoing statements
were given by him voluntarily and of his own free will.
ADMINISTERING OFFICER