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REPUBLIC OF THE PHILIPPINES)

PROVINCE OF CAMARINES SUR


CITY OF NAGA ) SS
xxxx----------------------------------xxxx

COMPLAINT-AFFIDAVIT

1. That, I, MARLA GAZA MERILLES, legal age, a resident of Zone 3, San Francisco, Magatao, Camarines
Sur, a registered owner of a black Mitsubishi Adventure Wagon bearing plate number ACR 2181, that in
the afternoon of January 28, 2023, I permitted or authorized my son Brian Merilles y Gaza to use and
drive the said vehicle together with her classmates.

That, the undersigned complainant under oath would like to file against Alfredo Grijalvo Jr. y
Moreno, 54 years old, widow, driver, Cadlan, Pili, CamSur, with Contact No. 09704911934, holder of
DL No. E07-99-008953, a case of reckless imprudence resulting in damage to property, committed as
follows;

3. That, at approximately 6:53 p.m. On December 27, 2022, while I together with my child was
driving along Maharlika Highway, Naga City, using my Champagne Utility Vehicle Avanza 1.3J M/T
bearing plate number TCQ197, registered under my name, from Del Rosario, Naga City, facing and
going in the direction of Rutonda, upon reaching the place besides the Coca-Cola Building, situated on
the right side of the Maharlika Highway in Concepcion, Pequeña, Naga City, I was stopped by the
security guard of the said building for a long truck bearing plate number AAV6402 to maneuver
backward on the highway where I was driving and which was my right of way;

4. That, after I was stopped and another rider of a motorcycle that was on the right side of my
car was stopped, the guard returned to the Coca-Cola gate and talked to other guards. Meanwhile, the
truck was driving aggressively, slanting, and while approaching the back part of it in my car, I horned it
for a long time, but it continued to maneuver without precaution. It hit and bumped the front left side
of my vehicle, resulting in damage to my vehicle.

5. That it resulted in me together with my child a serious fear and nervous, I did not move my
car, and the said security guard was come to me and asked my driver’s license and photograph it until
the police officers arrived,

6. That it resulted in me and my child having a serious fear and feeling nervous, I did not move
my car, and the said security guard came to me and asked for my driver’s license and photographed it
until the police officers arrived.

7. That, meanwhile, this is my statement: that I will elaborate and provide more details about
the incident in court if called to testify.

SUBSCRIBED AND SWORN to me before this ___ day of February 2023, in the City of Naga,
Philippines and I further certify that I have personally examined the affiant and that I am fully
satisfied that he voluntarily executed the foregoing instrument and that he fully understands his
statements contained therein.

PCDL Lipones, reported after having investigated a vehicular incident that transpired at about 2:51 PM of
January 28, 2023, at Peiñafrancia Avenue, Naga Gity, specifically in front of Bray. Peñafrancia Hall, wherein
Vehidle 1, a black Mitsubishi Adventure Wagon bearing plate no. ACR 2181, registered to Marla Gaza
Merilles of Zone 3, San Francisco, Magatao, Camarines Sur, being driven by Brian Merilles y Gaza, 20 years
old, single, cóllege student, also a resident of the same address, holder of DL no. E04-21-201527, with Cp
no. 09614103119, while travelingin said location, facing Brgy. San Felipe, upon reaching the scene of the
incident, was accidentally hit by Vehicle 2, a Honda CCG125 MII with a side car bearing plate no. 176 EOA
registered to Francis O Bonit of #79 Zone 6, Bell, Magara0, Camarines Sur, being driven by Rene Rosal y
Belda, 40 years old, single with a live-in partner, driver, High School graduate, a resident of Corner
Palomares St., Tinago, Naga City, holder of DL NO1-06-016927, who was traveling in the opposite direction,
inadvertently took the right of way of V1, after the Vehicle
Republic of the Philippines --- }
Province of Camarines Sur -- } S.S.
City of Naga --------------------- }
x------------------------------------- x

Affidavit of Complaint

1. That, I, MARLA GAZA MERILLES, legal age, a resident of Zone 3, San


Francisco, Magarao, Camarines Sur, after having sworn to in accordance with laws, do
herby depose and state;

 2. That, I the undersigned is a legitimate registered owner of a black Mitsubishi


Adventure Wagon bearing plate number ACR 2181, that in the afternoon of January 28,
2023, I permitted or authorized my son Brian Merilles y Gaza to use and drive the said
vehicle together with her classmates going to Naga City.

3, That, in the same afternoon, my son Brian informed me through a cellphone call
that while he was traveling along Peńafrancia Road, my car was hit by a Honda CCG125
MII with a sidecar bearing plate number 176 EOA (private) that was traveling in the
opposite direction, suddenly stopped, and turned towards our right of way, hitting my car
in the front left side.

4. That driver was identified as Rene Rosal y Belda, 40 years old, single with a
live-in partner, driver, High School graduate, a resident of Corner Palomares St., Tinago,
Naga City, holder of Drivers License no. NO1-06-016927. And

5. That, I executed this affidavit to attest the truthfulness of the forgoing facts
and for the purpose of filling a complaint against the above-mentioned motorcycle rider
Rene Rosal y Belda of a case of Reckless Imprudence Resulting in Damage to
Property.

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