REPUBLIC OF THE PHILIPPINES

Department of Interior and Local Government

BARANGAY PINSAO PROPER
BAGUIO CITY, PHILIPPINES

February 5, 2018

TO: HON. PEDRO DELA CRUZ

Barangay Chairman

Mr. MARIO R. TORRES

Complainant,

- Against- For: Slight Physical Injuries

Mr. JUAN S. MIGUEL and

Mr. JUN S. MIGUEL

Respondents.
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COMPLAINT

COMPLAINANT respectfully state: That,

1. I, MARIO R. TORRES, 23 years of age, Filipino citizen, single, is

residing at No. 48 Tacay Road, Brgy. Pinsao Proper, Baguio City

2. The respondents are:

(a) JUAN S. MIGUEL, 25 years of age, Filipino, single and with

residence at No. 15, Stone Crusher, Brgy. Pinsao Proper, Baguio
City, Benguet, where summon may be served;

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 (b) JUN S. MIGUEL, 24 years of age, Filipino, single and with
residence at No. 15, 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 about 7:00 in the evening of February 4, 2018, I went to

Zarate Village, located at Tacay Road, Barangay Pinsao Proper,
Baguio City to play basketball with my friends. Upon reaching
the basketball court of the village, my friends told me that we
will be having a friendly game with the team of Juan Miguel and
Jun Miguel. During the game, there has been a tension created
between us on the beginning of the last quarter since the game
was tight and intense with a score of 78-77, in favor of our team.

(b) Later on, at around 9:00 the game was finished and eventfully
my team won the game. After the said game, Mr. Juan Miguel
and Mr. Jun Miguel approached me at our bench and asked for
a rematch the next day but I refused and said that I have other
things to do. Due to the same, both of them got irritated and a
heated argument ensued between us saying that I was arrogant
and that I played unfairly. My teammates then interrupted the
argument stating that it is just a game and we can play again
next time. After which, our teams left the basketball court. My
team then proceeded to one our teammate’s house to have our
dinner.

(c) At around 11:45 in the evening, I left the said residence and
started to walk home. As I was approaching near a store, I saw
Juan Miguel and Jun Miguel having a drinking spree at the other
side of the street. They asked me to join them, but I refused and
said that it was already late.

(d)While I was walking away, I heard Juan Miguel and Jun Miguel
shouting “puro yabang ka lang naman,gago!” and suddenly, I
felt like a bottle hit the back of my left leg and heard that the

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 bottle broke when it hit the ground. I then heard Aling Nena,
the owner of the store, scream as she saw what the two men just
did. Then I saw Juan Miguel and Jun Miguel running towards
their house at Stone Crusher.

(e) I then continued to walk towards my house. My uncle, Ramon

Torres, who was waiting for me at the doorstep noticed that my
left leg is bleeding caused by the piece of the broken beer bottle
protruding at my wound. I told him what happened earlier and
that Juan Miguel and Jun Miguel are the persons responsible for
my injury.

(f) My uncle helped me and sent me to the Benguet General

Hospital to have an examination of my injuries that I have
sustained. Dr. Dy Lim, the doctor who attended me
recommended healing and rest period of nine (9) days. Attached
is 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 statements of a witness (Annex C).

THEREFORE, 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 the
medical expenses that I have incurred and pay for the days that I lost my
possible income at my work. 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: 179-707-089-000
COMPLAINANT

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