Republic of the Philippines

Autonomous Region in Muslim Mindanao

Regional Trial Court
Branch 9, Marawi City, Lanao Del Sur

Madz Mangorobong,
Plaintiff, Civil Case No. 000882
For: Damages
- versus -

Joanna Marie B. Alfaras,

Defendant.
x -------------------------- x

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff is a Filipino, of legal age, and resident of Saduc

Proper, Marawi City; defendant is also a Filipino, of legal age and resident
of MSU Marawi City, where he may be served with summons and other
processes.
2. On or prior to January 25, 2019, Basak Malutlut Street and
Awar Street were public roadways in Marawi City, Lanao Del Sur,
Philippines.
3. On or about 4 O’clock PM of January 25, 2019, Plaintiff, was
operating a 2017 TOYOTA FORTUNER on Basak Malutlut Street on route
from Lancaf to Sarimanok near its intersection of Awar Street, in Marawi
City, Lanao Del Sur, Philippines.
4. At the aforementioned time and place, Defendant, was
operating a 2018 FORD EVEREST on route from New Capitol to Basak
Malutlut on Awar Street near its intersection of Basak Malutlut Street, in
Marawi City, Lanao Del Sur, Philippines
5. At the aforementioned time and place, Defendant, while
attempting to turn left at the intersection of Basak Malutlut Street and Awar
Street, drove an automobile into and collided with the automobile being
driven by Plaintiff.
6. In breach of duty of care, Defendant was guilty of following
negligent acts:
(a) Failure to observe the necessary care in operating her automobile;
(b) Failure to insure that the intersection was clear of vehicular traffic
prior to initiating her left turn;
(c) Failure to slow or stop her automobile to avoid colliding with the
automobile of the plaintiff;
(d) Was otherwise careless and negligent.
7. As a direct and proximate cause of the foregoing negligent acts
of the defendant, plaintiff sustained serious and permanent injuries in his
lower limbs; was required to seek extensive medical consultation and
treatment; has expended, and will in the future expend, great sums of money
to be healed and cured of his condition; suffered, and will in the future
continue to suffer, great pain, anguish and physical and mental suffering;
and was deprived of earning of which he might have otherwise been entitled.
8. As a direct and proximate cause of the foregoing negligent acts
of the defendant. Plaintiff sustained damages to the vehicle; has expended,
and will in the future expend, great sums of money to fix this vehicle.
WHEREFORE, Plaintiff, prays for judgment against defendant, in
such an amount in excess of this Court’s jurisdictional requisite as will fairly
and adequately compensate Plaintiff for his injuries, losses and damages as
herein above alleged, costs of suit, and any further relief which this
honorable Court finds fair and just.
Marawi City, Philippines, 18 February 2019.

(Sgd.) ATTY. FAHDI M. MALIK

Counsel for Plaintiff
Address: Bangon, Marawi City