Complaint Affidavit .docx

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Republic of the Philippines SUPREME COURT METROPOLITAN TRIAL COURT IN CITIES National Capital Judicial Region 3/F, Justice Hall Quezon City Hall, Quezon City

Peter Banag, Plaintiff,

Civil Case No. 2345

-versus-

FOR: Damages

Arthur Sison, Defendant. - - - - - - - - - - - - - - - - - - - - - -x

COMPLAINT COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court, most respectfully avers: 1.

2.

3. 4.

5. 6. 7.

That the plaintiff, PETER BANAG, is of legal age, Filipino Citizen, married and a resident of No. 16 Annapolis, St., Cubao, Quezon City, Metro Manila, Philippines. That the defendant, ARTHUR SISON, is of legal age, Filipino Citizen, single and a resident of No. 12 Annapolis, St., Cubao, Quezon City, Metro Manila, Philippines. That the plaintiff’ is the father of Mary Banag, who was bitten by a dog owned by the defendant. That in the afternoon of 12 September at No. 24 Annapolis, St., Cubao Quezon City, Philippines. The daughter of the plaintiff was headed to the house of the defendant to buy ice candy where she was bitten by the dog of the latter. After which said victim was brought to the clinic by the defendant for treatment. That the plaintiff asked the defendant to pay P 20,000.00 in damages for the injury caused towards her daughter. That the defendant only replied to the plaintiff through a letter explaining he has no liability to pay for said damages. By reason of the failure of the defendant to pay the damages, the plaintiff was compelled to file this complaint.

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PRAYER WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that judgement be rendered ordering the defendant: 1. 2.

To pay for the damages of P 20,000.00 for the injury caused of the dog bite to Mary Banag. To pay the plaintiff the cost of the suit.

Plaintiff likewise prays for such other reliefs that are deemed just and equitable under the premises. Quezon City, Philippines, October 30, 2018

Atty. Lawrence Esio Counsel for the Plaintiff PTR No. 19808545; 09-16-17 IBP No. 784084; 09-16-17 Roll No. 53592; 07-16-15; Manila Rm. 10 2/F ABC Building, Pasig City, Metro Manila, Philippines

VERIFICATION/ CERTIFICATION OF NON-FORUM SHOPPING

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I, PETER BANAG, of legal age, Filipino, after having been sworn, in accordance with law, hereby depose and state that: 1.

I am the Plaintiff in the above-captioned case;

2.

I have read and understood the contents hereof of this Petition, and the facts herein alleged true and correct of my own knowledge and bases on available verifiable records;

3.

I heretofore have not commenced any other action or proceeding or any claim, or filed any claim involving the same issues raised in the above-captioned case, in this Honorable Court, nor in any other court or tribunal or agency and, to the best of my knowledge, no such other action to claim is pending therein;

4.

I hereby undertake to notify this Honorable Court of such fact within five (5) days from receipt of such knowledge, should I come to learn that the same or a similar actions or claim has been filed or pending in the Supreme Court, Court of Appeals, the different Divisions thereof, or any other court or tribunal or agency;

5.

I am executing this sworn statement in compliance with Section 5, Rule 7 of the Rules of Court.

Peter Banag Affiant

SUBSCRIBED and SWORN TO before me this 30th day of October 2018 at Quezon City, Philippines, affiant exhibiting to me his Drivers License with License No. HO2-16-003532 issued by the Land Transportation Office, as competent evidence of his identity,

4 and he personally acknowledged to me that the forgoing “Petition” is his free and voluntary act and deed. Machine copy of this Drivers License is hereto attached.

Atty. Czarenah Peach F. Redubla Notary Public PTR No. 9876543, Pasay City, 01/02/18 IBP OR No. 578497, Pasay City, 01/02/18 Attorney’s Roll No. 33388 MCLE Compliance Certificate No. IV-0036526 Pasig City, 01/02/18

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