Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR
PROVINCE OF ISABELA
City of Ilagan

ISABELINO ROMOSS,
Complainant,
NPS Docket No. II-04-INV-18F-
00492

FOR:
- versus -
RECKLESS IMPRUDENCE
RESULTING IN SERIOUS PHYSICAL
INJURIES UNDER ART 365 IN
RELATION WITH ART 263 OF THE
RPC
ANDRES TACLOBAN
Respondent

x- - - - - - - - - - - - - - - - -x

COMPLAINT

Complainant, through the undersigned counsel, and unto

this Honorable Court, most respectfully avers:

1. That complainant Isabelo Romoss is of legal age, Filipino

Citizen, and a resident of Fermeldy, Tumauini, Isabela,
where he may be served with summons and other
processes of this Honorable Court;

2. That he is a passenger of Victory Liner Bus with Plate No.

BAB 102 from Sampaloc, Manila en route to Tuguegarao
City, Cagayan;

3. That respondent Andres Tacloban is of legal age, Filipino

Citizen, and a resident of Echague, Isabela is a driver of
Victory Liner Incorporation who is a domestic corporation
duly organized and existing under the virtue of the laws of
the Philippines, with principal place of business at
Caloocan City, Manila;
 4. That on April 1, 2019 at around 4:30 in the morning along
Minante Uno, Cauayan City, Isabela, while respondent
Andres Tacloban is travelling from Tuguegarao City,
Cagayan did then and there willfully, unlawfully and
feloniously drive, manage and operate the same in a
reckless, careless, negligent and imprudent manner,
without regard to traffic laws, rules and regulations and
without taking necessary care and precaution to avoid
injuries to person, causing by such negligence, carelessness
and imprudence said driver collide with another vehicle;

5. As consequence due to the strong impact, complainant

trembled and fall from his seat and as a result he suffered
bodily injuries which required medical attendance for a
period of three (3) days from April 1,2019 to April 3,2019,
and incurred the amount of Eight Thousand Five Hundred
Pesos (8,500.00) as hospitalization expense as a result he
have become incapacitated from performing his
customary labor since the accident;

6. The report from the PNP Cauayan City clearly establishes

the recklessness of the respondent Andres Tacloban. Here
is to attach the copy of the police report which is attached
as ANNEX “A” and made an integral part of this complaint;

PRAYER

WHEREFORE, it is respectfully prayed to this Honorable Court

to render a decision after proper hearings to award the
complainant:

1. Actual damages including medical expenses incurred by

the complainant amounting to Eight Thousand Five
Hundred Pesos (P8,500.00);

2. Moral Damages of Five Thousand Pesos (P5,000.00);

3. Exemplary Damages of Five Thousand Pesos (P5,000.00) for

gross negligence for failing to observe extraordinary
diligence.

4. Attorneys Fee in the amount of Three Thousand Pesos

(P3000.00)
 Other remedies and reliefs which are just and equitable are
likewise prayed for.

Roxas, Isabela, April 21, 2019.

ATTY. REINA NOREEN A. IGNACIO

Counsel for the Plaintiff
Attorney’s Roll No. 48521
IBP No. 319067, Isabela, 01-09-17
PTR No. 2947091, Roxas, Isabela, 1-10-17
MCLE COMPLIANCE NO. IV 0018903 until 5-5-2022

Ignacio Law Office

Bantug, Roxas, Isabela
Telephone No. +63 905 7909 101
reinaignacio@gmail.com
 VERIFICATION / CERTIFICATION
OF NON-FORUM SHOPPING

The UNDERSIGNED, whose personal circumstances had

been mentioned earlier, after having been duly sworn to in
accordance with law, do hereby depose and say:

That I am the COMPLAINANT in the above-entitled Complaint;

That I have caused the preparation and filing of the foregoing

COMPLAINT and the allegations thereof are true and correct of
my own knowledge and belief and based on authentic records;

That I have not commenced any action or proceeding involving

the same issue/s in the Supreme Court, Court of Appeals,
different divisions thereof or any tribunal or agency. And if I
should hereafter learn that a similar action or proceeding has
been filed or pending in the Supreme Court, Court of Appeals
different divisions thereof or any tribunal or agency, I undertake
to inform the said court and this Honorable Court within five (5)
days there from.

IN WITNESS WHEREOF, I have hereunto set my hands on this

April 21, 2019, at Roxas, Isabela.

ISABELO ROMOSS
Affiant
Driver’s License No. B09-10-000681
Valid Until: 2019-03-07

SUBSCRIBED AND SWORN to before me this April 21, 2019, at

Roxas, Isabela.

Doc. No.: 54; ATTY. REINA NOREEN A. IGNACIO

Page No.: 7; Notary Public Until December 31, 2020
Book No.: 2; Roll No. 48521
Series of 2019 IBP No. 319067, Isabela, 01-09-17
PTR No. 2947091, Roxas, Isabela, 1-10-17
MCLE COMPLIANCE NO. VI 0018903 until 5-5-
2022