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Heirs of Domingo Salazar (Represented by Celia Salazar)
Heirs of Domingo Salazar (Represented by Celia Salazar)
CARLOS CORTEZ,
Defendant,
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COMPLAINT
7. That due to the recklessness, lack of foresight and lack of skill of the
defendant while driving the Toyota Fortuner with Plate No. FUB 036
at a high speed, the defendant lost control causing the vehicle to
swerve to the opposite lane and into the sidewalk where it hit the
plaintiff;
9. That the plaintiff clearly saw and vividly remembers that the Toyota
Fortuner that hit her was bearing the FUB 036 as the road was well lit
during the incident, a copy of the police blotter is hereunto attached
and marked as ANNEX C and made an integral part hereof;
10. That due to the incident, the plaintiff sustained serious physical
injuries resulting to his death, a copy of the plaintiffs medical
certificate and death certificate is hereunto attached and marked as
ANNEX D and ANNEX E and made an integral part hereof;
11. That due to the seriousness of the injuries sustained by the plaintiff,
she was confined for a period of two (2) days at Baguio General
Hospital, Baguio City incurring a hospital bill amounting to One
Hundred Ninety Eight Pesos (198,000.00 php), a copy of the
plaintiffs hospital bill is hereunto attached and marked as ANNEX
F and made an integral part hereof;
12. As a result of the Plaintiffs death his heirs also suffered mental
anguish and sleepless nights and is therefore entitled to moral
damages amounting to not less than 50,000.00 php;
13. That the plaintiff was forced to engage the services of the
undersigned counsel to protect her right for fee of 20,000.00php;
14. That an order to teach defendant a lesson so as to observe traffic rules
and regulations and to serve as deterrent to others, defendant should
be adjudged to pay exemplary damages of not less than 30,000.00php.
Other reliefs and remedies as may be deemed just and equitable under the
premises are also prayed for.
City of Baguio, Febuary 13, 2016
CELIA SALAZAR
Affiant
ID NO. SSS-123456
ISSUED AT BAGUIO CITY
ISSUED ON JANUARY 6, 2016