EXERCISE NO.

4
AFFIDAVIT

I, JUAN CARLO MIGUEL ,Filipino, of legal age, married and a resident of San
Jose, Digos City, Davao del Sur, Philippines, after being sworn in accordance
with law, depose and state:

1. That I am a duly licensed driver with Driver's License No. 12345, which
is valid until the year 2021 and that I usually drive a vehicle in bringing
my son to school at Digos Montessori, which vehicle is specifically
described as a Ford Everest, with Motor No.5678 and plate number
236789, issued by the Land Transportation Office of the City of Davao
and is registered in the name of my wife, Linda Miguel, with Certificate
of Registration No. 7890;

2. That on July 3, 2019, in the morning, at 7 o’clock a.m., when I brought

my son to school, who is an only child, and when the said vehicle was
parked in front of Digos Montessori School, alongside other vehicles,
one of which is a Nissan Navara, with plate number 0987, orange in
color, driven by someone who brought a student to Digos Montessori;

3. That after the student who alighted from the said Nissan Navara, had
entered the school gate, the driver of the said Nissan Navara,
recklessly and imprudently, tried to make a U-Turn and hit / bumped
my vehicle and that when I instantaneously blew my horn, the driver
of the said Nissan Navara quickly accelerated and feloniously fled away
in the direction going to the left, when you are facing the school;

4. That as a result of the incident, the Ford Everest I was driving

sustained damage in its rear portion, left side, and the damage was
noticeable;
 5. That the said incident was witnessed by many persons, around ten of
them and most of whom are also parents of students who were
likewise bringing their children to school, and the incident has been
duly documented in the Blotter of the Traffic Division of Digos City
Police Station by Pat. Michael Vista;

6. That upon inquiry with the Security Office of the Digos Montessori, it
was discovered that the said Nissan Navara has been issued a Car Pass
by the school upon application of a certain Joel Vios, a parent of a
Grade 5 student of Digos Montessori, with residence at Brgy. Tres De
Mayo, Digos City.

7. That I am executing this Affidavit to attest to the truth of the foregoing

and in support of charges for "RECKLESS IMPRUDENCE" against the
driver of the said Nissan Navara or for whatever other action that may
be filed against the driver and/or registered owner of the said vehicle
and in support of claims against the insurer for the repair of the
damage caused to the vehicle I was driving.

IN WITNESS WHEREOF, I have hereunto set my hand this 4th of July, 2019,
Digos City, Davao del Sur, Philippines.

JUAN CARLO MIGUEL

AFFIANT