Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Manila

SPS. FLORENTINO
Plaintiffs,

-versus Civil Case No. 123456789

FOR: Damages

MAHALEN CORPORATION,
Defendants.
x--------------------------------------x

COMPLAINT

PLAINTIFFS, by and through the undersigned counsel and unto this

Honorable Court most respectfully allege that:

1. The Plaintiffs SPS. FLORENTINO are spouses, both Filipino, of

legal age and residents of 108 Ilacanos Sur, San Fernando City, La
Union, Philippines.

2. The Defendant Partak Bus Company is a domestic corporation

duly organized under the laws of the Philippines engaged in the business of
land transportation of passengers and goods and a holder of certificate of
public convenience with principal place of business at 640 Quezon Avenue,
Quezon City, Philippines, where it may be served with summons and other
court processes. A copy of the certificate of public convenience is hereto
attached as Annex “A”;
 DAMAGES

3. As a result of defendants’ fault or negligence constituting

quasi-delict, they are liable to plaintiff for damages.

4. Because of the incident, plaintiff has had to undergo

monthly check-ups thereby unnecessarily incurring expenses in the amount
of not less than PhP 300,000.00.

5. In addition to the physical injuries and pain, plaintiff

Filemon Arviso has also suffered and is still suffering mental anguish, severe
anxiety and psychological torture caused by the incident. He has been
suffering from sleepless nights and tormented by financial expenses which
could have been avoided, thereby entitling her to moral damages in the
amount of, at least, PhP 400,000.00.

PRAYER

WHEREFORE, PREMISES CONSIDERED, plaintiff, through the

undersigned counsel most respectfully prays on this Honorable Court, after
due hearing, to adjudge defendants Paolo Ololo and Northern Line Bus
Company jointly and severally, to pay the plaintiff the following:
1) Seven Hundred Thousand Pesos (Php 700,000.00) as
actual or compensatory damages representing the hospitalization and
medical expenses of the plaintiff;
2) Five Hundred Thousand Pesos (PhP 500,000.00) for
attorney’s fees and One Hundred Thousand Pesos (100, 000.00) for
litigation expenses;
3) Other just and equitable reliefs are, likewise, prayed for.

RESPECTFULLY SUBMITTED this 6 August 2016 at San Fernando

City, La Union, Philippines.
 FILOMINO AVISO and FILOMINA AVISO
Plaintiffs

Assisted by

HIDALGO ESTEPHA AND ASSOCIATES LAW OFFICES

319-A, 3rd floor, Diocesan Center, Gomez Street, San Fernando City, La
Union, Philippines.
e-mail: HEAlawoffices@gmail.com
telephone number: 082-296-123

JURAT and CERTIFICATION

I, FILOMINO AVISO, after having been sworn to in accordance with

law hereby depose and say THAT:

1. I am one of the plaintiffs in the above-entitled case;

2. I have caused the preparation and filing of the foregoing

complaint, that I have read the allegations therein, and that they are
 true and correct of my own personal knowledge and belief and based
on authentic documents;

3. Other than the foregoing complaint, I have not commenced any

other action or proceeding involving the same issue before the
Supreme Court or Court of Appeals or any divisions thereof or before
any tribunal or agency and that, to the best of my knowledge, there is
no such action or proceeding pending before any tribunal;

4. If other than the foregoing complaint, I should learn that a similar

action or proceeding has been filed or is pending in any tribunal, I will
notify this Honorable Court of the same within five (5) days from such
notice

IN WITNESS WHEREOF, I have hereunto set my hand this 6, August

2016 at San Fernando City, La Union, Philippines.

SUBSCRIBED AND SWORN TO before me a Notary Public, for and

in the City of Davao, the affiant, Filomino Aviso exhibited to me her current
and unexpired driver’s license numbered L02-123456 valid until May 1,
2015, bearing her photograph and signature as competent proof of her
identity.

CINDY SORIANO
Doc No.: 50 Notary Public for La Union

Page No.10 Notarial Commission No. 123-2012

PTR No. 123456; 01-02-13;D.C.
Book No.II
IBP Life Member Roll 12348
Series of 2016.
MCLE Compliance No. III-123459; 01-
10-2012
Issued at Manila City