Subpoena Receiving

Republic of the Philippines
DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Muntinlupa City
ROQUE SR., HARROLD NPS Docket No. 0000-453-654

Complainant,
For: Reckless Imprudence
- versus – Resulting to Multiple Physical
Injuries
RUN, BONG
Respondent
X------------------/
SUBPOENA
MR. BONG RUN

138 M. Zosa, St. Poblacion
Muntinlupa City
Under and by virtue of the authority vested in me by law,

you are hereby directed to submit your counter-affidavit and
other supporting documents or affidavits of your
witness/es if any, to be sworn before me on or before March
28, 2021 at Muntinlupa City Hall, National Road,
Putatan, Muntinlupa City. Attached here is a copy of the
complaint and other evidence submitted by the complainant.
You are hereby WARNED that failure on your part to

comply with the subpoena shall be considered as a waiver of
your right to present your defense and the case shall be
considered submitted for resolution based on the evidence on
record. Likewise, no motion to dismiss in lieu of your counter-
affidavit shall be entertained in accordance with Section 3, Rule
112 of the Rules of Court.
WITNESS MY HAND this 14th day of March 2021 at
Muntinlupa City, Philippines.
A.C.T.
Atty. Asis Ann C. Tee .
Assistant City Prosecutor
-------------------------------------------
CERTIFICATE OF SERVICE
This is to certify that this 14th day of March 2021, I have

served a copy of the SUBBPOENA upon the person/s to whom
it is addressed in accordance with law, and acknowledged
receipt of proper service as evidenced by his/her/their
signature/s made hereof by Bong Run in my presence.
Elbicp.
Elbi C. Padalla .
Process Server
___________________________________
Respondent’s Name and Signature
San Beda College Alabang
School of Law
Muntinlupa, Philippines
Complaint:
Reckless Imprudence Resulting to
Multiple Physical Injuries
Practice Court 2
Submitted to:
Atty. Roben Cadugo
Submitted by:
Group 3 (4A/4A1)
Baudi, Mary Antonnette
Bello, Nerissa
Lavalle, Edrich Javier
Pamonag, Armand Alfred
Rosete, Florence
Soriano, Maria Yna Krista
Tan, Mayrell
REPUBLIC OF THE PHILIPPINES
OFFICE OF THE PROSECUTOR
MUNTINLUPA CITY
ROQUE SR., HARROLD,

Complainant,
-VERSUS-
Case #
For: Reckless
Imprudence Resulting
to Multiple Physical
RUN, BONG,
Respondent. Injuries
x x
COMPLAINT AFFIDAVIT
I, HARROLD ROQUE, SR., Filipino, of legal age, married, with postal address at
XXXX, Muntinlupa City after being sworn in accordance with law, do hereby
depose and state that:
1. That I am a duly licensed driver with Driver's License No.88888888, which is

valid until the year 2025 and that I own and drive a vehicle, which vehicle is
specifically described as an Audi Q7 SUV with Motor No.12345, Chassis No.
54321 and with plate No.56789 issued by the Land Transportation Office of
the City of Muntinlupa and is registered in my name, with Certificate of
Registration No.98765 issued on 2010 and with MVMRR No. 2468 dated
January 2, 2010.
A copy of my Driver’s License is attached herein as “Annex A”, Deed of Sale
of Motorvehicle as “Annex B”, and LTO Certificate of Registration and
Official Receipt as “Annex C-1 and C-2”.;
2. In the morning of November 13, 2020, I was driving north along XXX Ave.
from the direction of Muntinlupa City in my vehicle with my wife MAHAL
ROQUE, and our three-year-old son HARROLD ROQUE, JR.
A copy of our marriage contract is attached here in as “Annex D”, and my

son’s birth certificate as “Annex E”.;
3. I turned left and was coming to the center of XXX Ave. when a speeding Isuzu
Elf Truck with plate no. ABC1234 driven by BONG RUN and coming from
Makati City headed south towards Muntinlupa City, suddenly overtook a big
truck from the right side.;
4. I tried to avoid the accident by reducing speed and swerving to the right
towards the shoulder of the road, but the Elf Truck was moving too fast and I
could not avoid the collision, despite my best efforts.;
5. The Isuzu Elf Truck then crashed into the right side of our vehicle at a right
angle.
6. That BONG RUN was driving his vehicle without taking the necessary
precaution to prevent injury to persons and damage to property, causing the
collision to occur, as evidenced by a police report detailing the incident.
A copy of the police vehicular accident report is attached “Annex F”;

7. The said incident is duly documented in the Blotter of the Police Community
Precint-6 of Muntinlupa City Police, which a copy is attached herein as
“Annex G”.;
8. All passengers of the SUV including myself were injured and immediately
brought to Hospital, Muntinlupa City.
9. While I suffered a complete fracture of the scapular bone of my right shoulder.
A copy of the medico legal certificate with regards to this injury is attached
herein as “Annex H”.;
10. My son, HARROLD ROQUE, JR. sustained abdominal injury and a wound
on the area of his right eye which required suturing, which required medical
attendance for ten (10) days;
A copy of the medico legal certificate with regards to this injury is attached
herein as “Annex I”.;
11. My wife, MAHAL ROQUE sustained an open fracture of the humerus of the
right arm and displaced, closed fracture of the proximal and distal femur of
the right lower extremity which required two surgical operations.
A copy of the medico legal certificate with regards to this injuries is attached
herein as “Annex J”.;
12. She was paralyzed as a result of the accident and was unable to return to her
job as the Regional Manager of STAR Product Laboratories.
A copy of certification from STAR Product Laboratories regarding the is
attached herein as “Annex K”.;
13. I spent about P50, 000.00 for my treatment, P25, 000.00 for my son’s
treatment, and P1, 500, 000.00 for my wife’s treatment.
A copy of the official receipts of this incident from the hospital is attached
herein as “Annex L-1, L-2, and L-3”.;
14. The damage sustained by the SUV reached P250,000.00.
A copy of the official receipt for repairs is attached herein as “Annex M”.;
15.That according to the official Blotter Report of Traffic Division of the

Muntinlupa City, that the Elf Truck with plate no. ABC1234 driven by BONG
RUN is owned by a RUDY DUMBAS of Makati City. (Refer to Annex G);
16. Based on the facts of the case all elements of Reckless Imprudence under
Article 365 of the Revised Penal Code are present to sufficiently charge the
respondent of the crime.;
17. It is clear that BONG RUN committed reckless imprudence and such actions
resulted to multiple physical injuries.; and
18. That I am executing this Affidavit to attest to the truth of the foregoing and in
support of charges for "RECKLESS IMPRUDENCE" against the driver of
the Isuzu Elf Truck for whatever other action that may be filed against the
driver and/or registered owner of the said vehicle and in support of claims for
the repair of the damage caused to the vehicle I was driving, and for the
medical expenses incurred.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that judgement be rendered in favour of the complainant for all
reliefs and remedies that the Honorable Court shall deem just and equitable.
This 8th of March, 2021 in Muntinlupa City, Philippines.
HARROLD ROQUE, SR.

Complainant/Affiant
SUBSCRIBED AND SWORN TO before me this 8th day of March 2021 in the City
of Muntinlupa, I hereby certify that I examined the affiant and am I am satisfied that
he voluntarily executed this Counter-Affidavit.
ASST. CITY PROSECUTOR

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING
I, Harrold Roque, Sr., Filipino, of legal age, married and a resident of at XXXX,
Muntinlupa City, after having been duly sworn to in accordance with law, do hereby
depose and state:
1. That I am the complainant in the above-entitled case;
2. That I have caused the preparation and filing of the foregoing complaint and have
read all the allegations therein which are true and correct based on my personal
knowledge and authentic documents;
3. That I further certify that there is no pending action or proceeding involving the
same issues in any court, tribunal, quasi-judicial agency, or any other similar agency.
If I should thereafter learn that the same or similar action is pending, I shall
undertake to inform the Honorable Court of this fact within five (5) days therefrom.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 8th day of

March 2021 in Muntinlupa City.
Harrold Roque, Sr.

Complainant/Affiant
SUBSCRIBED AND SWORN to before me on this 8th day of March 2021 at

Muntinlupa City, affiant exhibiting to me PHILIPPINE ISSUED PASSPORT No.
23132 which will expire on September 15, 2024 being sufficient and
competent evidence of her identity pursuant to the 2004 Rules of Notarial
Practice.
ABRAHAM TORRES
Notary Public for Muntinlupa City
Commission Serial No. 622372 Until
December 31, 2022 Roll of Attorney No.
51286
PTR No. 101112; 1/31/22;
Muntinlupa City IBP No. 810123;
2/18/22; Muntinlupa City
Doc. No. 20;

Page No. 44;
Book No. 13;
Series of 2021
MUNTINLUPA CITY
ROQUE SR., HARROLD,

Complainant,
-VERSUS-
Case #
For: Reckless
to Multiple Physical Injuries
RUN, BONG,
Respondent,
x x
JUDICIAL AFFIDAVIT OF MAHAL ROQUE

I, Mahal Roque, Filipino, of legal age, married, with postal address at XXXX,
Muntinlupa City, the witness for the complainant HARROLD ROQUE, SR. in
this case, state under oath as follows:
PRELIMINARY STATEMENT
The person examining me is Atty. Nelson Santos with address at XXXX,
Muntinlupa City. The examination is being held at the same address. I am
answering his questions fully conscious that I do so under oath and may face
criminal liability for false testimony and perjury.
PURPOSE
This Affidavit of Mahal Roque is being offered to prove that Respondent BONG
RUN has committed Reckless Imprudence under Article 365 of the Revised Penal
Code, resulting to multiple injuries.
1. Q: What is your name?

A: My name is Mahal Roque.
2. Q: Do you know the respondent, Bong Run?
A: Yes, sir.
3. Q: How do you know Bong Run?
A: He was the driver of Isuzu Elf Truck, with plate no. ABC1234, which
crashed into our car.
4. Q: When was that?
A: In the morning of November 13, 2020.
5. Q: Will you state for the record, the sequence of events which lead to the
Isuzu Elf Truck crashing into your car?
A: We were traversing XXX Ave., from the direction of Muntinlupa City
when Harrold turned left going to XXX Ave., the speeding Isuzu Elf Truck
was in our lane, overtaking a big truck from the right side.
6. Q: What did your husband do when he saw the incoming Isuzu Elf Truck?
A: He tried to avoid the truck, reducing his speed and swerving to the right
shoulder of the road, but we still collided with the truck because the truck
was moving too fast.
7. Q: Did you sustain any injuries during the collision?
A: Yes, my right arm was fractured as a result and was confined in the
hospital.
8. Q: How did you treat your injuries?
A: I had two surgical operations which cost P1,500,000.00 in total.
IN WITNESS WHEREOF, I have hereunto set my hand this 8th day of

March 2021 in Muntinlupa City, Philippines.
Mahal Roque
Complainant-Witness

54365 which will expire on August 15, 2023 being sufficient and competent
evidence of her identity pursuant to the 2004 Rules of Notarial Practice.
ABRAHAM TORRES
Notary Public for Muntinlupa City Commission
Serial No. 622372 Until December 31, 2022
Roll of Attorney No. 51286
PTR No. 101112; 1/31/22; Muntinlupa City
IBP No. 810123; 2/18/22; Muntinlupa City
Doc. No. 21;

Page No. 45;
Book No. 13;
Series of 2021
ATTESTATION
I, , of legal age, Filipino, with address at
, Muntinlupa City after being duly sworn depose
and say:
1. I was the one who conducted the examination of witness MAHAL ROQUE at
my aforementioned office in the same abovementioned address;
2. I have faithfully recorded or caused to be recorded the questions asked and the
corresponding answer that the witness gave; and
3. I nor any other person then present or assisting him coached the witness
regarding his answers.
IN WITNESS WHEREOF, I have hereunto set my hand this 8th day of March
2021 at Muntinlupa City, Philippines.
AFFIANT
23467 which will expire on September 15, 2024 being sufficient and competent
ABRAHAM TORRES
Doc. No. 22;

Page No. 46;
Book No. 13;
Series of 2021
MUNTINLUPA CITY
ROQUE SR., HARROLD,

Complainant,
-VERSUS-
Case #
For: Reckless
RUN, BONG,
Respondent,
x -------------------------------------------- x
JUDICIAL AFFIDAVIT OF JANE DELA CRUZ
I, Jane Dela Cruz, Filipino, of legal age, married, Human Resource Supervisor
of STAR Product Laboratories with postal address at XXXX, Muntinlupa City,
after having been sworn in accordance with law, by way of this Judicial Affidavit,
hereby testifies before this Honorable Court as follows:

PURPOSE
This Affidavit of Jane Dela Cruz is being offered to prove among others, that the
witness is a Human Resource supervisor at STAR Product Laboratories; and that
Mahal Roque, was not fit to return to work after being paralyzed as a result of the
accident.
1. Q: What is your name?
A: My name is Jane Dela Cruz.
2. Q: Where are you currently employed?
A: STAR Product Laboratories
3. Q: What is your position in STAR Product Laboratories?
A: Human Resource supervisor.
4. Q: Do you know Mahal Roque?
A Yes sir.
5. Q: How do you know Mahal Roque?
A: She is a regional manager at STAR Product Laboratories
6. Q: How long has Mahal Roque been employed as Regional Manager
of STAR Product Laboratories?
A: For almost 7 years now.
7. Q: What are the tasks of a Regional Manager? A:
The tasks are to determine the operational practices of all stores in the area,
making sure each runs smoothly, cleanly, complies with marketing and
sales campaigns and meets budget and sales goals.
8. Q: Having known the current condition of Mahal Roque, can she still fulfill
the job as Regional Manager? A: According to
the medical results that were sent to us, she is paralyzed and she will be
needing physical therapy for a long period of time with no certainty that
she can fully restore her abilities, we could conclude that she won’t be fit
to return back to work anytime soon.
9. Q: How long has it been since Mahal Roque was not able to come to work?
A: She has not been able to return to work for almost 4 months now.
Jane Dela Cruz

Affiant-Witness

Muntinlupa City, affiant exhibiting to me PROFESSIONAL REGULATION
COMMISSION LICENSE No. 11243538 which will expire on June 27, 2025
being sufficient and competent evidence of her identity pursuant to the 2004 Rules
of Notarial Practice.
ABRAHAM TORRES
Doc. No. 23;

Page No. 47;
Book No. 13;
Series of 2021
ATTESTATION
and say:
1. I was the one who conducted the examination of witness JANE DELA CRUZ,
at my aforementioned office in the same abovementioned address;
3. I or any other person then present or assisting him coached the witness regarding
his answers.
2021 at Muntinlupa City, Philippines.
AFFIANT

453454 which will expire on July 14, 2022 being sufficient and competent
ABRAHAM TORRES
Doc. No. 24;

Page No. 48;
Book No. 13;
Series of 2021
MUNTINLUPA CITY
ROQUE SR., HARROLD,

Complainant,
-VERSUS-
Case #
For: Reckless
RUN, BONG,
Respondent,
x -------------------------------------------- x
JUDICIAL AFFIDAVIT OF HARROLD ROQUE, JR.
I, Harrold Roque, Jr. Filipino, 3 years of age, single with postal address at
XXXX, Muntinlupa City, the witness for the complainant HARROLD ROQUE,
SR. in this case, state under oath as follows:

PURPOSE
This Affidavit of Harrold Roque, Jr. is being offered to prove that Respondent
BONG RUN has committed Reckless Imprudence under Article 365 of the
Revised Penal Code, resulting to multiple injuries.
1. Q: Hi little boy. What is your name?

A: My name is Harry Roque, Jr..
2. Q: How old are you?
A: I am 3 years old.
3. Q: Where do you live?
A: At home.
4. Q: Who is your father?
A: My father is Harry Roque, Sr.
5. Q: Who is your mother?
A: My mother is Mahal Roque.
6. Q: What happened to your right eye?
A: It’s because of the car.
7. Q: Does it hurt?
A: Yes.
8. Q: Aside from your right eye, what else hurts?
A: My stomach.
9. Q: Did you already go to the doctor?
A: Yes.
10. Q: What did the doctor told you?
A: To drink my medicine and rest.
2021 in Muntinlupa City, Philippines.
Harrold Roque, Jr.

Complainant-Witness

54645 which will expire on February 14, 2026 being sufficient and competent
ABRAHAM TORRES
Serial No. 622372Until December 31, 2022
Doc. No. 25;

Page No. 49;
Book No. 13;
Series of 2021
ATTESTATION
and say:
1. I was the one who conducted the examination of witness HARROLD ROQUE,
JR., at my aforementioned office in the same abovementioned address;
his answers.
AFFIANT
ABRAHAM TORRES
Doc. No. 26;

Page No. 50;
Book No. 13;
Series of 2021
MUNTINLUPA CITY
ROQUE SR., HARROLD,

Complainant,
-VERSUS- Case #
For: Reckless
Imprudence
Resulting
RUN, BONG, to Multiple Physical
Respondent. Injuries
x x
JUDICIAL AFFIDAVIT OF DR. MARK SANTOS
I, Dr. Mark Torres, Filipino, of legal age, Single, Resident Doctor at Hospital
with Postal Address at XXXX, Muntinlupa City, after having been sworn in
accordance with law, by way of this Judicial Affidavit, hereby testifies before
this Honorable Court as follows:

PURPOSE
This Affidavit of Dr. Mark Santos is being offered to prove among others,
that the witness is a Senior Physician at Hospital, Muntinlupa City and that
he has examined HARROLD ROQUE, SR., MAHAL ROQUE, AND
HARROLD ROQUE, JR. and the injuries they had incurred due to the
accident
1. Q: Please state your name and profession for the benefit of the court.
A: My name is Mark Torres, Senior Physician at Hospital, Muntinlupa
2. Q: Where are you practicing your profession and what position do you
currently hold?
A: I am currently a Senior Physician at Hospital, Muntinlupa City,
3. Q: How long have you been practicing your profession?
A: For almost 17 years now.
4. Q: Have you ever examined a man by the name of Harrold Roque, Sr.?
A: Yes. I have examined Harrold Roque, Sr. for complaint of physical
injuries due to the accident.
5. Q: What was your finding after conducting a medical examination of him?
A: After examination and reading of medical tests results, I have found
that he has incurred complete fracture of the scapular bone of the right
shoulder
6. Q: How about a woman by the name Mahal Roque, have you done any
examination on her?
A: Yes sir. I also examined her for complaint of physical injuries due to
the accident.
7. Q: What was your finding after conducting a medical examination of her?
A: She has sustained an open fracture of the humerus of the right arm and
displaced, closed fracture of the proximal and distal femur of the right
lower extremity which needed two surgical operations.
8. Q: Lastly, have you examined a child named Harrold Roque, Jr?
A: Yes, I have also examined him along with his parents
9. Q: What are your findings?
A: He sustained abdominal injury and a wound on the area of his right eye
which required suturing, which required medical attendance for ten (10)
days
10. Q: Do you have tests results to support such findings?
A: Yes. We have multiple test results to support the findings
11.Q: Did you prepare a medical report showing such findings?
A: Yes, Sir.
12. Q: I have here three documents from Hospital, Muntinlupa City entitled
Medico-Legal Certificate each for one Harrold Roque Sr., Mahal
Roque, and Harrold Roque, Jr. dated November 13, 2020, are these
familiar?
A: Yes, Sir.
13. Q: At the bottom of these documents entitled Medico-Legal Certificate,
there appears to be a name, Dr. Mark Santos with a signature over it. Is this
your name and signature?
A: Yes, Sir. That is my name and signature.
(Attached to this Judicial Affidavit are original copies of the

medico-legal certificates marked as Exhibit “H”, Exhibit “I”, and Exhibit
“J”)
IN WITNESS WHEREOF, I have hereunto set my hand this 8th day of
March 2021 in Muntinlupa City, Philippines.
Dr. Mark Santos

Complainant-Witness

Muntinlupa City, affiant exhibiting to me PROFESSIONAL REGULATION
COMMISSION LICENSE No. 11243538 which will expire on June 27, 2025
being sufficient and competent evidence of her identity pursuant to the 2004
Rules of Notarial Practice.
ABRAHAM TORRES
Doc. No. 27;

Page No. 50;
Book No. 13;
Series of 2021
ATTESTATION
and say:
1. I was the one who conducted the examination of witness DR. MARK
SANTOS, at my aforementioned office in the same abovementioned address;
his answers.
AFFIANT

ABRAHAM TORRES
Serial No. 622372 Until December 31, 2022 Roll
of Attorney No. 51286
Doc. No. 28;

Page No. 51;
Book No. 13;
Series of 2021
“ANNEX A”
!
“ANNEX B”
“ANNEX C”
C-1 & C-2
“ANNEX D”
!
“ANNEX E”
!
“ANNEX F”

National Police Commission
PHILIPPINE NATIONAL POLICE
POLICE COMMUNITY PRECINCT-6
XXXX, Muntinlupa City
National Capital Region
Email: pcp6_muntinlupa@yahoo.com Tel No. 8-7056734
FOR: Officer in Charge

National Capital Region Police Office
Southern Police District
Muntinlupa City Police Station

SUBJECT: Investigation Report Re: Alleged Reckless Imprudence Resulting to

Multiple Physical Injuries that transpired along XXXX Ave. Muntinlupa City

Date: November 13, 2020
I. Authority
1. Muntinlupa PCP-6 Blotter Entry no. 4567
2. Inherent Police Functions
3. Standard Operating Procedure

II. Matters Investigated:
4. To determine facts and circumstances surrounding the incident.
5. To determine other relevant matters that require further police actions.
6. To determine the damages incurred by Audi Q7 SUV with plate number
56789
III. Facts of the case:

7. On or about November 13, 2020, the Barangay Tanod Robert De Leon of
Brgy XXXX, Muntinlupa reported and sought police assistance on the
alleged vehicular accident at XXXX Ave., Muntinlupa City. PO2 Nicole Y.
Abante was dispatched and returned to the station together with the
alleged involved parties.

Upon confirmation, Harrold Roque Sr. and Mahal Roque, both Filipino
and of legal age, together with their son, were traversing XXXX Ave.,
Muntinlupa when a speeding Izuzu Elf Truck with plate number ABC1234
driven by Bong Run and coming from Makati City headed south towards
Muntinlupa City, suddenly overtook a big truck from the right side.

8. In the investigation conducted by the duty traffic officer in the alleged
vehicular incident, disclosed that after verification and ocular inspection, the
alleged damages revealed that the Audi Q7 SUV incurred damage on its right
side.
Follow up investigation conducted shows that all passengers of the
said vehicle sustained multiple physical injuries. The driver, Harrold Sr.
suffered a fracture of the scapular bone on the right shoulder. Her wife, Mahal
Roque, sustained an open fracture of the humerus of the right arm and
displaced, closed fracture of the proximal and distal femur of the lower
extremity. The son sustained abdominal injury and wound on the area of his
right eye.

9. In the statement of Robert De Leon, single and resident of XXXX,
Muntinlupa City, that while in the performance of his duty as Brgy. Tanod,
he saw the incident. He then asked help for first aid services but seeing
how severe the injuries were, he then decided to call for an ambulance.
Also, he went to the nearest police station and asked for assistance.
IV. Discussions/Findings
10. In the instant case under investigation, both parties have a respective
allegation related to the incident. In the statement of Mr. Roque Sr, he
avers that he tried to avoid the accident by reducing speed and swerving
to the right towards the shoulder of the road, but the Elf Truck was
moving too fast. The driver of the Izuzu Elf Truck posits that he needed to
overtake since the big truck was driving way ward.

V. Recommendation:
11. Wherefore, in view of the foregoing, the undersigned respectfully
recommends that the debris recovered and both vehicles will undergo
field laboratory examination and parties involved will file their separate
complaint against each other.

Prepared by:
Nicole Y. Abante
Police Officer II

Noted by:

Armand Alfred A. Dela Cruz
Police Inspector, Chief Investigation Section

Approved by:

Alex S. Reyes
Police Superintendent
Officer-in-Charge
“ANNEX G”

National Police Commission
PHILIPPINE NATIONAL POLICE
POLICE PRECINCT-6
XXXX, Muntinlupa City
National Capital Region
Email: pcp6_muntinlupa@yahoo.com Tel No. 8-7056734

OFFICE OF THE CHIEF OF POLICE

Police Blotter:
As per report and records of events available in the official police blotter
of this office there appears the following data, to wit:

Police blotter series of –2020
Police blotter page number—123
Police blotter entry number—4567
Date and Time Entered---- November 13, 2020

Facts of the case:

(RECKLESS IMPRUDENCE RESULTING TO MULTIPLE PHYSICAL INJURIES):
One Harrold Roque Sr., together with his family, was traversing XXXX Ave.,
Muntinlupa City when a speeding Izuzu Elf Truck with plate number ABC1234
drivern by Bong run and coming from Makati City headed south towards
Muntinlupa, suddenly overtook a big truck from the right side.

Damages were evident from both cars and that the family of Mr. Roque all
sustained life threatening injuries that required them medical attention.

Prepared by:
Nicole Y. Abante
Police Officer II

Noted by:
Armand Alfred A. Dela Cruz
Police Inspector, Chief Investigation Section
“ANNEX K”
STAR PRODUCTS LABORATORIES
CERTIFICATION
This is to certify that Ms. MAHAL ROQUE is an employee of STAR PRODUCTS
LABORATORIES from 2014 to present and is holding the position of a Regional

Manager.
However, Ms. MAHAL ROQUE is currently on indefinite leave since November 16,
2020 due to being temporarily incapacitated as evidenced by medical records submitted
to the Human Resources Department to physically perform her duties after meeting a
vehicular accident on November 13, 2020.
This certificate is being issued upon her request for whatever legal purpose it may
serve her.
Issued on 2nd March 2021, Muntinlupa City.
Jane Dela Cruz

Supervisor
Human Resources Department
“ANNEX L”
L-1
“ANNEX L”
L-2
“ANNEX L”
L-3
“ANNEX M”

Subpoena Receiving

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Republic of the Philippines

ROQUE SR., HARROLD NPS Docket No. 0000-453-654

MR. BONG RUN

Under and by virtue of the authority vested in me by law,

You are hereby WARNED that failure on your part to

This is to certify that this 14th day of March 2021, I have

ROQUE SR., HARROLD,

1. That I am a duly licensed driver with Driver's License No.88888888, which is

A copy of our marriage contract is attached here in as “Annex D”, and my

A copy of the police vehicular accident report is attached “Annex F”;

9. While I suffered a complete fracture of the scapular bone of my right shoulder.

14. The damage sustained by the SUV reached P250,000.00.

15.That according to the official Blotter Report of Traffic Division of the

This 8th of March, 2021 in Muntinlupa City, Philippines.

HARROLD ROQUE, SR.

ASST. CITY PROSECUTOR

1. That I am the complainant in the above-entitled case;

IN WITNESS WHEREOF, I have hereunto affixed my signature this 8th day of

Harrold Roque, Sr.

SUBSCRIBED AND SWORN to before me on this 8th day of March 2021 at

Doc. No. 20;

ROQUE SR., HARROLD,

JUDICIAL AFFIDAVIT OF MAHAL ROQUE

1. Q: What is your name?

IN WITNESS WHEREOF, I have hereunto set my hand this 8th day of

SUBSCRIBED AND SWORN to before me on this 8th day of March 2021 at

Doc. No. 21;

Doc. No. 22;

ROQUE SR., HARROLD,

JUDICIAL AFFIDAVIT OF JANE DELA CRUZ

The person examining me is Atty. Nelson Santos with address at XXXX,

Jane Dela Cruz

SUBSCRIBED AND SWORN to before me on this 8th day of March 2021 at

Doc. No. 23;

SUBSCRIBED AND SWORN to before me on this 8th day of March 2021 at

Doc. No. 24;

ROQUE SR., HARROLD,

JUDICIAL AFFIDAVIT OF HARROLD ROQUE, JR.

The person examining me is Atty. Nelson Santos with address at XXXX,

1. Q: Hi little boy. What is your name?

Harrold Roque, Jr.

SUBSCRIBED AND SWORN to before me on this 8th day of March 2021 at

Doc. No. 25;

Doc. No. 26;

ROQUE SR., HARROLD,

JUDICIAL AFFIDAVIT OF DR. MARK SANTOS

The person examining me is Atty. Nelson Santos with address at XXXX,

(Attached to this Judicial Affidavit are original copies of the

Dr. Mark Santos

SUBSCRIBED AND SWORN to before me on this 8th day of March 2021 at

Doc. No. 27;

SUBSCRIBED AND SWORN to before me on this 8th day of March 2021 at

Doc. No. 28;

Republic of the Philippines

FOR: Officer in Charge

SUBJECT: Investigation Report Re: Alleged Reckless Imprudence Resulting to

III. Facts of the case:

Republic of the Philippines

STAR PRODUCTS LABORATORIES

This is to certify that Ms. MAHAL ROQUE is an employee of STAR PRODUCTS

LABORATORIES from 2014 to present and is holding the position of a Regional

2020 due to being temporarily incapacitated as evidenced by medical records submitted