Republic of the Philippines)

Pasig City…………………….) Sc.

COMPLAINT-AFFIDAVIT
I, LIECA C. BALAYANTO, of legal age, Filipino, and a resident of
#22 Westbank Road, Barangay Maybunga, Pasig City, after having been duly
sworn to an oath in accordance with law hereby depose and state:

1. That I am a duly licensed driver with Driver’s License Number

N01-18-020651which is valid until the year 2033;

2. That I usually drive a vehicle to school at Centro Escolar

University, Mendiola, Manila, which vehicle is specifically
described as Toyota Raize 1.2 G CVT S2-003 with engine
number WA0034532, chassis number MHKAB1BA2NJ011213,
bearing plate number NFE1171 issued by the Land
Transportation Office of Pasig City and is registered in the name
of Marvin Cantillana Merjudio with certificate of registration
number 452391822, issued on June 23 2022;

3. That on April 13, 2023 at around 6:20 in the morning while

driving the above-said vehicle along F. Legaspi Street west
bound Barangay Maybunga, Pasig City, and on a full stop due
to a traffic congestion at the said area, another vehicle identified
as a Toyota VIOS 1.3 XLE CV bearing plate number DAT9169,
registered in the name of a certain Alexander Rosel Sulit and
which was being driven by a certain Moniboy Macal Amoncio
recklessly, imprudently and without regard to traffic rules and
regulations, bumped my vehicle from behind;

4. That as a result of the strong impact my vehicle sustained

damages on different parts namely hematite, right rear bumper
cover, right rear lower cover, back door panel, back glass
spacer, left hand back glass clip, right hand glass clip and right
rear bumper left hand molding. Consequently, the total amount
needed for the repair and restoration of said damaged parts
reached to fifty-seven thousand three hundred two pesos and
thirty centavos (Php57,302.00) (Photographs of damaged parts
and copy of Job
 Estimate hereto attached and made an integral part of this
Complaint-Affidavit);

5. That I immediately reported the incident to the Pasig Police

Station who investigated and recorded the same in their blotter
and indexed as Blotter Entry No. T-2023-04-0774 (Copy of
Traffic Accident Investigation Report hereto attached and made
an integral part of this Compliant-Affidavit);

6. That initially the said Moniboy Macal Amoncio promised to

defray the expense for the repair of my vehicle, however after a
series of talks with him, he suddenly could no longer be
contacted despite
several attempts and a formal demand, thus creating a strong
belief on my part that he now has intentionally absconded from
his liability;

7. That the elements of reckless imprudence are as follows ; (1)

that the offender does or fails to do an act; (2) that the doing or
the failure to do that act is voluntary; (3) that it be without
malice; (4) that material damage results from the reckless
imprudence; and (5) that there is inexcusable lack of precaution
on the part of the offender, taking into consideration his
employment or occupation, degree of intelligence, physical
condition, and other circumstances regarding persons, time,
and place;

8. That all the above-cited elements are present in this incident,

first in bumping my car from behind the respondent Moniboy
Amoncio clearly failed to take the necessary precautions and
applied his driving skills such as reducing the speed of his
vehicle and observing safe distances in order to avert the
collision, second, that his failure to avoid the collission,
although not malicious was voluntary on his part as there was
no outside force which caused his vehicle to bump me from
behind other than that of his failure to exercise due diligence in
operating his car, third as a result of the collission my vehicle
sustained multiple and material damages, finally in operating
his vehicle at such speed, which can be reasonably drawn from
the extent of the resultant damage, at said time and the traffic
condition then obtaining at the place of the incident,
demonstrated inexcusable lack of precaution on the latter's
part;
 9. Finally, I am executing this Complaint-Affidavit freely and
voluntarily to attest to the truthfulness and veracity of the
foregoing facts and to support the filing of charges for Reckless
Imprudence Resulting in Damage to Property against Moniboy
Amoncio y Macal of Upper Cuatro, Barangay San Juan, Cainta,
Rizal, as may be warranted by the foregoing allegations.

IN WITNESS WHEREOF, I have hereunto set my hand

this_____________________ in Pasig City, Philippines.

LIECA C. BALAYANTO
Complainant

SUBSCRIBED AND SWORN to before me this____day of July 2023

at Pasig City, Philippines. I HEREBY CERTIFY that I have personally
examined the herein complainant and I am satisfied that she voluntarily
executed and understood her given affidavit.

_________________________
_________________________
_________________________
Republic of the Philippines)
Pasig City…………………….) Sc.

COMPLAINT-AFFIDAVIT

I, POLICE STAFF SERGEANT ZOSIMO D. CALDA JR., of legal

age, Filipino, and with Office Address at Pasig City Police Station,Pasig City,
after having been duly sworn to an oath in accordance with law hereby depose
and state:

1. That I am a member of the Philippine National Police and

currently assigned with the Pasig City Police Station and
designated as Traffic Accident Investigator;

2. That at about 6: 58 in the morning of April 13, 2023, a certain

Lieca C. Balayanto reported to our station regarding a traffic
accident involving her driven Toyota Raize 1.2 G CVT S2-003
SUV bearing plate number NFE1171 and a Toyota VIOS 1.3
XLE CV bearing plate number DAT9169, registered in the name
of a certain Alexander Rosel Sulit and which was being driven
by a certain Moniboy Macal Amoncio, a resident of Upper
Cuatro, Barangay San Juan, Cainta, Rizal. I accordingly
responded to and investigated the matter;

3. That my inquiry disclosed that that prior to the incident the

vehicles involved were traversing the same direction along F.
Legaspi Street west bound Barangay Maybunga, Pasig City
toward general direction, wherein Vehicle 1 (Toyota Raize SUV)
is ahead of Vehicle 2 (Toyota VIOS Sedan). That upon reaching
the place of occurrence vehicle 1 was in full stop because of the
traffic congestion during that time, and at that juncture vehicle
2 coming from behind accidentally bumped the rear portion of
vehicle 1. That as a result thereof, said vehicles involved
incurred undetermined number of damages;
 4. That I recorded the incident in our police blotter indexed as
Blotter Entry No. T-2023-04-0774 and accordingly prepared a
Traffic Accident Investigation Report;

5. That initially the parties orally agreed to settle the incident

amicably wherein Moniboy Macal Amoncio, apparently
admitting fault over the incident, promised to defray the
expense for the repair of the Toyota Raize SUV;

6. That I latter on learned from the complainant Lieca C.

Balayanto that the offending driver Moniboy Amoncio
absconded from his obligation;

7. Finally, I am executing this Affidavit freely and voluntarily to

attest to the truthfulness and veracity of the foregoing facts and
in support to the filing of charges against Moniboy Amoncio for
reckless imprudence resulting in damage to property.

IN WITNESS WHEREOF, I have hereunto set my hand

this_____________________ in Pasig City, Philippines.

PSSG ZOSIMO D. CALDA JR.

Affiant

SUBCRIBED AND SWORN to before me

this_______________________ at Pasig City, Philippines.