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Republic of the Philippines


Metropolitan Trial Court
National Capital Judicial Region
Branch ___
Quezon City

MARY BANAG, minor represented CIVIL CASE NO. ___


by her father PETER BANAG, FOR: DAMAGES BASED
Plaintiffs, ON QUASI-DELICT

-versus-

ARTHUR SISON,
Defendant.
x----------------------------------------x

COMPLAINT
(with Prayer for Payment of Damages)

Plaintiff, through counsel, unto this Honorable Court most


respectfully states that:

PARTIES

1. The herein Plaintiff is a minor who is represented by her father of


legal age, married and a resident of 16 Annapolis St., Cubao, Quezon
City.

2. The Defendant is of legal age, married and a resident of 12 Annapolis


St., Cubao, Quezon City.

3. For cause of action against the Defendant, it is hereby stated that on


September 12, 2018, at about three o’clock in the afternoon, while
Defendant Arthur Sison was sleeping in his house, he so negligently
and recklessly unlocked his gate where a dog is kept inside;

4. Because of this, the Defendant’s dog jumped out and bit Plaintiff
Mary on her arms and leg as she was trying to buy ice-candy from the
sleeping Defendant;

5. Upon seeing the incident, Witness Fred Puzon immediately ran to


help Mary by kicking the dog away;
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6. The Defendant was awakened by the commotion. He stepped out into


the street and sent the dog inside.

7. The Defendant called a tricycle and brought Mary to a medical clinic


nearby for treatment in which he paid for the medical bill.

8. Due to the incident, Plaintiff Mary suffered anguish and serious


anxiety.

9. Plaintiff Peter Banag asked Defendant Arthur Sison to pay her


daughter, Mary, ₱20,000 in damages for what she suffered.

10.Through a letter, Defendant Arthur Sison promptly denied liability for


reason that he already paid for the medical bill.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed


of this Honorable Court that judgment be rendered in favor of the plaintiff
and that after judgment, the defendant shall pay ₱20,000 as moral damages
for the injuries Mary suffered.

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

Quezon City, Philippines, this 30th day of October 2018.

ATTY. ELLEN JOY D. DEBUTON, RPm


Counsel for the Plaintiff
Roll of Attorney No. 65888
IBP No. 1088000/01/10/2022/Quezon City
PTR No. 7588888/01/19/2022
MCLE Compliance No. VI-0008888
Valid Until April 14, 2027
Helpful Lawyer’s Office, Eklavu Building
Magsais Boulevard, Quezon City
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VERIFICATION AND CERTIFICATION OF NON-FORUM


SHOPPING

I, MARY BANAG, as represented by PETER BANG of legal age,


married and a resident of 16 Annapolis St., Cubao, Quezon City, after being
sworn according to law, hereby depose and state that;

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true
and corner of my personal knowledge and/or on the basis of copies
of documents and records in my possession;

4. I have not commenced any other action or proceeding involving


the same issues in the Supreme Court, the Court of Appeals, or any
other tribunal or agency;

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


proceeding is pending in the Supreme Court, the Court of Appeals,
or any other 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, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

In witness thereof, I have hereunto set my hand this 30 th of October at


Quezon City.

SUBSCRIBED AND SWORN to before me this 30th day of


October, 2018, by Peter Banag, who exhibited to me his Voter’s ID No.
80808 issued at Quezon City, Philippines on May 12, 2016.

THEZZALLONA A. ALISTAIR
NOTARY PUBLIC
Commission Expires on December 31, 2020
IBP Lifetime No.2088870; Quezon City
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PTR No. 2088870; April 14, 2022, Quezon City


Roll of Attorney No. 2088870
MCLE Compliance No. 2228888

Doc. No. 088;


Page No. 08;
Book No. 021;
Series of 2018.

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