Affidavit Complaint Against Nathaniel XXXXXXXXXXXX

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Republic of the Philippines ]

City of Baguio ] S.S.


x----------------------------------x

AFFIDAVIT COMPLAINT against NATHANIEL XXXXXXXXXXXX

I, NOEL XXXXXXXXX, of legal age, married, Filipino citizen and a resident of


Pico, La Trinidad, Benguet, under oath, state that:

1. I am the owner of a Toyota Innova Taxi with plate number XXX 1234;

2. I bought said motor vehicle from Toyota Bokawkan, Deed of Sale of Motor
Vehicle vehicle’s Official Receipt and Certificate of Registration hereto attached
as Annexes “A,” “B,” “C”;

3. As mentioned on the attached certification from Baguio Police Station 5 at


Legarda, on August 17, 2021 at around 10pm nighttime, my driver Hamilton
XXXXX called to inform me that my taxi unit he was driving was bumped by a
rainbow colored Toyota Grandia with plate number XXX 999;

4. My driver told me that the driver of the other vehicle immediately removed his
grandia away from the taxi instead of waiting for police to take pictures of the
incident and make a report. My driver took a picture of the ID of the driver whose
name was certain XXXXXXXXXXXXXX, resident of Aurora Hill, Baguio City;

5. The driver did not appear in the police station despite his promise to go after
answering his phone that he will go to the police station, even telling my driver to
wait for him. My driver finally went home past midnight after waiting for 2 hours;

6. The next day, he sent a message to my driver telling him to give an estimate of the
vehicle’s damages for him to pay. When he again called the grandia driver so they
could meet to give the bill, the grandia driver was not answering the calls;

7. My driver went to the police station to report that the grandia driver was no longer
answering his calls, so the police officer also tried calling the number but there
was still no answer;

8. A copy of the quotation and list of expenses related to the damage to our vehicle
due to reckless imprudence of the grandia driver is hereto attached as Annex “D”;

9. Up to now, no updates have been received from this grandia driver, particularly
how they would settle the amount for the repair of the damaged Toyota Innova
taxi unit;

10. I am executing this Affidavit to attest to the truth of the foregoing to support my
complaint for Reckless Imprudence Resulting in Damage to Property and all other
appropriate charges as may be warranted by the circumstances, against
XXXXXX, as well as pertaining to the renewal of his driver’s license, that it
would not be renewed pending this incident for blatantly escaping his
accountability for the damages he caused to my taxi unit and the expenses that
came along with it.

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


May 2021 in the City of Baguio, Philippines.

NOEL XXXXXXXXXXXX
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this 23rd day of August 2021


in the City of Baguio, Philippines, affiant personally appeared and exhibited to me his
driver’s license N12-345678-9 valid until 2022/12/02.

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