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Republic of the Philippines

REGIONAL TRIAL COURT

_______Judicial Region

Branch 33

Bauang La union

GENER S. ROMERO

Plaintiff, CRIMINAL CASE NO._____

For: RECKLESS IMPRUDENCE

with Less Serious Physical Injuries and

Damaged to Property

-versus-

GIRLIE B. FLORES

Respondent

COMPLAINT

PLAINTIFF, by counsel, unto this honorable court respectfully states and prays
that:

1.Both plaintiff and respondent are Filipinos of age. Plaintiff is a resident of

Sibuan-Otong san Fernando city La Union, while respondent is a resident of #30
Chico St., Sta.Rosa Pasig city.

2.That on July 1,2018, while Romulo with her daughter were traversing in their
motorcycle the national highway at Brgy.Pagdalagan sur, Bauang La Union, Girlie
B. Flores car bumped them. The said accident was caught by a CCTV, entered into
police blotter at PNP Bauang La Union station.

3. Romulo and her daughter were rushed to the Ilocos Sur training and regional
Medical Center(ITRMC) at Parian, san Fernando City, La Union for treatment and
eventually, confined for six days because of the injuries he sustained.

4.Romulo’s motorcycle was also damaged due to the incident, and was estimated
to spent Php 6,400 for repair.

5.Romulo was not able to work for 20 days to recover as advised by his physician,
thus forcing him to take a leave from work.

6. Because of the incident, Romulo including his family also suffer mentally or
psychologically injury due to sleepless nights and anguish when girlie B. Flores,
the one who caused the accident, did not fulfill her promise to shoulder all the
finances he incurred which was not limited to hospital bills, repair of the
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motorcycle, and medication. His wife was also forced to work to provide for the
family’s everyday needs during the days Romulo was not able to work. Her
daughter, though did not suffer physically, she wakes up trembling and crying
with fear dreaming of the accident for days.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

honorable court that judgement be rendered in favor of the Plaintiff and that
after judgement:

a. The defendant shall be ordered to pay all the expenses incurred by the plaintiff
in his hospitalization and medication, to pay for the estimated cost for repair for
the damaged motorcycle, and to pay for attorney’s fees.

b. Such other reliefs and remedies under the premises are likewise prayed for.

Bauang La Union, Philippines, this 25th of July 2018.

Counsel for the Plaintiff

Atty. Vina langiden-Sambu

Atty.Mary grace Gurtiza

Atty. Diane Faye Laigo

Atty. Rhenallyn Nisperos

Atty. Gillian Joy Siobal

Atty. Daryll Macagba

Atty. Melvin Micu

Rm. 8 2/F Zambrano bldg.

Ortega Rd, San Fernando City La Union

VERIFICATION AND NON-FORUM SHOPPING

I, Romulo S. Gener, of legal age, after having been duly sworn in accordance with
law, hereby, depose and state that:

1.I am the Plaintiff in the above case;

2.I caused the preparation of the foregoing case;

3.I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of documents
and records in my possession;
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4.I have not commenced any other action or proceeding, involving the same
issues to any court or other tribunal or agency;

5.To the best of my knowledge and belief, no such action or proceeding is

pending in the Supreme Court, Court of Appeals, or any tribunal or agency;

6.If I should thereafter learn that a similar action or proceeding has been filed or
is pending before the Supreme Court, Court of Appeals, or any tribunal or agency,
I undertake to report that fact within 5(five)days therefrom to this Honorable
Court.

___________________________________

Affiant

SUBSCRIBED AND SWORN to before me this 25th day of July,2018, at San

Fernando City La union affiant exhibiting to me his Community Tax Certificate No.
_____________ issued on June 12,2018 at San Fernando City.

Doc.No.;

Page No.;

Book No.;

Series of 2018

ACKNOWLEDGEMENT

BEFORE ME a Notary Public for and in the City of San Fernando La Union,
personally appeared with _____________ Community Tax Certificate No. 112415,
issued at San Fernando City known to me and known to be the same person who
executed the foregoing instrument which he acknowledged to me as his free and
voluntary act and deed. Acknowledgement is written duly signed by him and his
witnesses on each and every page hereof.

WITNESS MY HAND AND SEAL this 25th day of July 2018 at San Fernando City La
Union, Philippines.

NOTARY PUBLIC

Doc. No._____________;

Page NO._____________;

Book No._____________;

Series No._____________;