REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
MAKATI CITY
BRANCH 147
ATTY. PETE T. UY,
Plaintif,
-versus- CIVIL CASE NO. 14-00069
FOR: DAMAGES
DR. SARAH BU-TAN,
Defendant
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C O M P L A I N T
Plaintif Atty Pete T. Uy (hereinafter referred to as
Plaintif), by counsel, to this Honorable Court, respectfully
states that:
1.Plaintif is a Filipino, of legal age, single, and a
resident of No. 9, Narra Street, Forbes Park, Makati
City.
2.Defendant Dr. Sarah Bu Tan (hereinafter referred to as
Defendant) is a physician, Filipino, of legal age, single,
and residing at Room 41, One Salcedo Place,
Tordesillas Street, Makati City, where she may be
served with summons and other processes of this
Honorable Court.
3.Sometime in October 2013, Plaintif went to the clinic
of the Defendant situated in her residence above-
mentioned to inquire whether the Defendant caters
organ enlargement operation.
4.A week later, Plaintif received a Quotation from the
Defendant stating therein that the operation package
is at Five Hundred Thousand (Php500,000.00) Pesos
and if Plaintif is amenable thereto, he must afx his
signature above his typewritten name (A copy of which
is hereto attached as Annex A).
5.Plaintif found the Quotation of the Defendant
reasonable and so he afxed his signature above his
typewritten name under the word Conforme (Annex
A-1). Thereafter, Plaintif sent the said payment to
the Defendant and the latter acknowledged receipt
thereof (Annex A-2).
6.On November 15, 2013, the actual operation was
conducted to the Plaintif by the defendant and upon
the latters advice, Plaintif must take the prescribed
medicine for two (2) weeks, make the necessary
cleaning and come back to her clinic for post-
operation check up day thereafter. However, prior
thereto, pictures were taken showing the appearance
of Plaintifs penis prior to the operation (Pictures are
attached as Annexes B to B-4).
7.Plaintif complied with such advice and came back to
the Defendants clinic on December 2, 2013. However,
Defendant noticed that his penis shrinked/deformed
instead of enlarging as desired.
8.Plaintif sought the opinion of other surgical doctors
and the latter made fndings that indeed there was
something unusual with the operation conducted by
the Defendant and/or the medicines used in the
conduct thereof.
9.Several demands were made by the Plaintif to the
Defendant for the correction of such operation but the
same were ignored by the Defendant (Annexes C and
D).
10. As a result of Defendants negligence and
imprudence, Plaintif sufered damages amounted to
One Million Pesos (Php1,000,000.00) as he was
deprived of his right to enjoy of his manhood and his
opportunity to look for his prospective partner.
11.To protect his rights and interests, plaintif was
constrained to engage the services of a counsel for an
agreed attorneys fees equivalent to 25% of the total
amount due, plus appearance fee for every court
hearing, which expenses should be paid by the
defendant.
P R A Y E R
WHEREFORE, Plaintif prays before this Honorable Court that
judgment be made in his favor by ordering defendant to pay
the amounts of:
1.One Million Pesos (Php 1,000,000.00) as actual damages
2.Five Hundred Thousand Pesos (Php500,000.00) as moral
damages
3.Five Hundred Thousand Pesos (Php500,000.00) as
exemplary damages
4.Attorneys fees equivalent to 25% of the total amount due
plus appearance fee for every court hearing and costs of
suit.
OTHER JUST AND EQUITABLE RELIEFS and remedies
are prayed for.
Done. Makati City, Philippines. 30
th
July 2014.
PRADAC LAW OFFICE
37th Floor, LKG Tower
6801 Ayala Avenue
Makati City
ATTY. MAE SABIT
PTR 345765, 1/10/15, Makati City
IBP No. 01032 Lifetime Member
Roll No. 37453
No. 1 Maaralin St. cor. MatatagSt.
Brgy. Central, Makati City
Philippines
Republic of the Philippines)
Makati City...) S.S.
VERIFICATION AND CERTIFICATION
ATTY. PETE T. UY, after having been sworn to in
accordance with law, states and declares that he is the
plaintif in the above-entitled complaint, that he has caused
the preparation of the above complaint and has read and
knows the same; the allegations therein are true to his own
personal knowledge, and he has not fled or commenced any
action or proceeding involving the same issues nor is there any
proceeding or action pending before the Supreme Court, Court
of Appeals or in any tribunal or agency involving the same
parties and issues, and in the event that Plaintif would know
that there is an action or proceeding involving the same issues
and parties, he undertakes to notify this Honorable Court of
the pendency of such action within fve (5) days from
knowledge thereof.
ATTY. PETE T. UY
SUBSCRIBED AND SWORN to before me this 30
th
day of July
2014 at Quezon City, Philippines by afant showing his CTC
No. 05409598, issued on 4
th
January 2014 at Makati City,
Philippines.
ATTY. VINALYN POTOT
PTR 548985, 1/10/15, Makati City
IBP No. 54568 Lifetime Member
Roll No. 37453