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Complaint Damages
Complaint Damages
ALEJANDRO BUTAL,
Plaintiff, Civil Case No. ___________
FOR:
-versus-
DAMAGES
DIMPOL BUROLLO and
PHILIPPINE KUNEHO BUS,
Defendants.
x-----------------------x
COMPLAINT
1. Plaintiff is of legal age, married, Filipino citizen and with residence and
Philippines;
3. Sometime on July 28, 2006, Plaintiff boarded the 11:00 o’clock A.M. trip of
AVS 848 bound for San Fernando, La Union. As such, he was issued a
bus ticket hereto attached and marked as Annex “A” and made integral
part hereof;
4. At around 11:45 o’clock in the morning, while said bus was traversing at
and steel fence at the shoulder of the road owned by Thor Magtanggol.
The incident was reported to the Burgos Police Station, La Union for
5. As a result of the vehicular incident and aside from the damages incurred
6. With the assistance of the persons present at that time, all the passengers
who sustained injuries including the Plaintiff were rushed to the nearby
treatment;
7. Plaintiff was then treated at said hospital where series of x-rays were
his foreleg, he went for radiology and medical treatment at the Baguio
General Hospital & Medical Center, Baguio City. Copy of the findings is
Lines at their branch office located along Governor Pack Road, Baguio
City for the refund of all Plaintiff’s expenses he incurred as a result of the
vehicular incident but such demands were only landed to a deaf hears;
10. In view of the unwarranted display of bad intent of the Defendant – Driver
12. As a consequence of the injuries the Plaintiff failed to earn for a living
mental anguish and undue irritation and vexation whereby moral damages
13. The wanton disregard of the safety of the public and traffic rules and
14. Despite due demands made against the Defendants to compensate the
Plaintiff to hire the services of a counsel whose fees are agreed upon in
15. Considering that Plaintiff has been compelled to litigate his claims against
PRAYER
this Honorable Court that after due notice and hearing, judgement be rendered,
ordering the Defendants jointly and solidarily to pay unto the Plaintiff;
By:
________________________
Counsel for the Plaintiff
PTR. No. 1643125:1-5-06;B.C.
IBP. No. 643559:1-5-06;B.C.
Roll No. 43631:5-5-99;Mla.