Republic of the Philippines

Municipal Trial Court

Angeles City

Rico, Leilani, Myrna

Complainants.

-Versus- CC No. xxxxx

For: Reckless
Imprudence Resulting in
Damage to Property and
Physical Injuries
Francis Morales
Respondent.

x---------x
COMPLAINT-AFFIDAVIT

Complainants, through counsel, unto the Honorable Court, most respectfully

alleges, that:

THE PARTIES

1. Complainant, Rico is of legal age, Filipino, single and a resident of xxx,

xxx. He may be served with notices and court processes through his
undersigned counsel;

2. Complainant, Leilani is of legal age, Filipina, single and a resident of xxx,

xxx. She may be served with notices and court processes through her
undersigned counsel;

3. Complainant, Myrna is of legal age, Filipina, single and a resident of xxx,

xxx. She may be served with notices and court processes through her
undersigned counsel;

4. Complainant, Albert Vital is of legal age, Filipino, single and a resident of

xxx, xxx. He may be served with notices and court processes through his
undersigned counsel;

5. Respondent, Francis Morales is of legal age, Filipino, single and a

resident of xxx, xxx, where he may be served with summons and court
processes.
 FACTS CONSITUTING COMPLAINANTS' CAUSE OF ACTION

6. Complainant Rico is the driver of a jeepney with Plate No. CWR-138

with Leilani, Myrna and Albert Vital as passengers.

7. At 3:00 a.m. of May 15, 2013 the jeepney driven by Rico is traversing
from Maimpis to Angeles City Market, while the Delica driven by Francis
Morales with Plate Number XKZ528 on the opposite lane is traversing
towards San Fernando;

8. The Delica recklessly driven by Francis Morales suddenly overtook the

vehicle in front of him and occupied the lane of the jeep driven by Rico,
causing the collision between the vehicles;

9. The jeepney took an extensive damage of P350,000.00 due to the

collision;

10. The driver Rico, suffered deep laceration on the forehead and a cervical
strain which required treatment and hospitalization amounting to
P14,345.00;

11. While, Leilani sustained skin and soft tissue avaltion, posterior lateral
aspect on the right forearm and sprain ankle, with hospitalization cost of
P34,763.50;

12. Myrna suffered multiple physical injuries and incurred damages in the
amount of P3,045.00;

13. Albert Vital incurred hospitalization expenses in the amount of

P2,895.80;

14. That complainants formally charge the respondent, Francis Morales of

the crime of Reckless Imprudence Resulting in Damage to Property and
Physical Injuries

ACTS CONTRARY TO LAW

City of Angeles, Philippines, (Date)

Rico, Leliani, Myrna, Albert

Vital
Complainants

SUBSCRIBED and SWORN to before me, the undersigned

prosecutor, this x day of x, xxxx in the City of Angeles, Philippines. I hereby
certify that I have personally examined the above-named affiant and that I
am satisfied that the foregoing statements were given by them voluntarily
and if their own free will.

Notary Public