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Republic of the Philippines

SUPREME COURT
METROPOLITAN TRIAL COURT IN CITIES
National Capital Judicial Region
3/F, Justice Hall
Quezon City Hall, Quezon City

Peter Banag,
Plaintiff, Civil Case No. 2345
-versus- FOR: Damages
Arthur Sison,
Defendant.
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COMPLAINT

COMES NOW, the plaintiff, through the undersigned counsel and unto
this Honorable Court, most respectfully avers:

1. That the plaintiff, PETER BANAG, is of legal age, Filipino Citizen,

married and a resident of No. 16 Annapolis, St., Cubao, Quezon City,
Metro Manila, Philippines.
2. That the defendant, ARTHUR SISON, is of legal age, Filipino Citizen,
single and a resident of No. 12 Annapolis, St., Cubao, Quezon City,
Metro Manila, Philippines.
3. That the plaintiff’ is the father of Mary Banag, who was bitten by a dog
owned by the defendant.
4. That in the afternoon of 12 September at No. 24 Annapolis, St., Cubao
Quezon City, Philippines. The daughter of the plaintiff was headed to the
house of the defendant to buy ice candy where she was bitten by the dog
of the latter. After which said victim was brought to the clinic by the
defendant for treatment.
5. That the plaintiff asked the defendant to pay P 20,000.00 in damages for
the injury caused towards her daughter.
6. That the defendant only replied to the plaintiff through a letter explaining
he has no liability to pay for said damages.
7. By reason of the failure of the defendant to pay the damages, the plaintiff
was compelled to file this complaint.
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PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

unto this Honorable Court that judgement be rendered ordering the defendant:

1. To pay for the damages of P 20,000.00 for the injury caused of the dog
bite to Mary Banag.
2. To pay the plaintiff the cost of the suit.

Plaintiff likewise prays for such other reliefs that are deemed just and
equitable under the premises.

Quezon City, Philippines, October 30, 2018

Atty. Lawrence Esio

Counsel for the Plaintiff
PTR No. 19808545; 09-16-17
IBP No. 784084; 09-16-17
Roll No. 53592; 07-16-15; Manila
Rm. 10 2/F ABC Building, Pasig City,
Metro Manila, Philippines

VERIFICATION/ CERTIFICATION OF NON-FORUM

SHOPPING
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I, PETER BANAG, of legal age, Filipino, after having been sworn,

in accordance with law, hereby depose and state that:

1. I am the Plaintiff in the above-captioned case;

2. I have read and understood the contents hereof of this Petition,
and the facts herein alleged true and correct of my own
knowledge and bases on available verifiable records;
3. I heretofore have not commenced any other action or
proceeding or any claim, or filed any claim involving the same
issues raised in the above-captioned case, in this Honorable
Court, nor in any other court or tribunal or agency and, to the
best of my knowledge, no such other action to claim is pending
therein;
4. I hereby undertake to notify this Honorable Court of such fact
within five (5) days from receipt of such knowledge, should I
come to learn that the same or a similar actions or claim has
been filed or pending in the Supreme Court, Court of Appeals,
the different Divisions thereof, or any other court or tribunal
or agency;
5. I am executing this sworn statement in compliance with
Section 5, Rule 7 of the Rules of Court.

Peter Banag
Affiant

SUBSCRIBED and SWORN TO before me this 30th day of October

2018 at Quezon City, Philippines, affiant exhibiting to me his
Drivers License with License No. HO2-16-003532 issued by the
Land Transportation Office, as competent evidence of his identity,
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and he personally acknowledged to me that the forgoing “Petition”

is his free and voluntary act and deed. Machine copy of this Drivers
License is hereto attached.

Atty. Czarenah Peach F. Redubla

Notary Public
PTR No. 9876543, Pasay City, 01/02/18
IBP OR No. 578497, Pasay City, 01/02/18
Attorney’s Roll No. 33388
MCLE Compliance Certificate No. IV-0036526
Pasig City, 01/02/18

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