REPUBLIC OF THE PHILIPPINES Department of Interior and Local Government BARANGAY PINSAO PROPER BAGUIO CITY, PHILIPPINES February 9, 2019 TO: HON. PEDRO DELA CRUZ Punong Barangay
Mr. MARIO A. TORRES Complainant, - Against-
For: Slight Physical Injuries
Mr. JUAN S. MIGUEL and Mr. JUN S. MIGUEL Respondents. x----------------------------------------x COMPLAINT COMPLAINANT respectfully state: That, 1. I, MARIO A. TORRES, 29 years of age, Filipino citizen, single, is residing at No. 05 Tacay Road, Brgy. Pinsao Proper, Baguio City. 2. The respondents are: (a) JUAN S. MIGUEL, 27 years of age, Filipino, single and with residence at No. 25 Stone Crusher, Brgy. Pinsao
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Proper, Baguio City, Benguet, where summon may be served; (b) JUN S. MIGUEL, 22 years of age, Filipino, single and with residence at No. 25 Stone Crusher, Brgy. Pinsao Proper, Baguio City, Benguet, where summon may be served; 3. That the facts of the case are as follows: (a) On or around 12 midnight of February 5, 2019, I was walking in Zarate Village, located at Tacay Road, Barangay Pinsao Proper, Baguio City, on my way home from a birthday party. I was slightly inebriated due to the beer I had drunk during the said party and was at first unable to recognize the two men sitting at the side of the street in front of the sari-sari store who were shouting obscenities at me. (b)Upon reaching a sari-sari store, Juan Miguel and Jun Miguel, herein respondents, who were drinking began throwing bottles of beer at me. A bottle hit me in the back of my left leg, causing a superficial wound. (c) Aling Nena Cruz, owner of the store, shouted at the two respondents to stop causing them to leave the premises and run to their house located at Stone Crusher, Barangay Pinsao Proper. (d) I continued my way home where my uncle Ramon Torres saw the bleeding wound inflicted by the bottle. My uncle drove and accompanied me to the Baguio General Hospital for first aid.
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(e) Dr. Dy Lim, the doctor who attended me disinfected and covered the wound with gauze. He recommended a rest period of nine (9) days. (f) After the first aid was administered, my uncle and I went to the Police Station 1 in Naguilian Road, Baguio City, to report the incident. (g)A copy of the medico legal certificate (Annex “A”), a police blotter acquired from Police Station 1 in Naguilian Road, Baguio City (Annex “B”), and the statement of a witness (Annex “C”) are attached. WHEREFORE, premises considered, it is respectfully prayed that immediate summons be issued to respondents and that immediate barangay conciliation/mediation meetings be held by the Barangay Lupon. I also respectfully pray that respondents will be held liable for actual, moral, and exemplary damages. The complainant reserves the right to file the proper criminal actions against the respondents Juan S. Miguel and Jun S. Miguel for the violations of the Revised Penal Code. Further, we pray for such and other reliefs as may be deemed just and equitable in the premises.
MARIO R. TORRES BIR TIN: 170-009-990-009 COMPLAINANT
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