Vincent Verzosa; Student # 17-00357

Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Branch ___, QUEZON CITY

GARDO DE LEON
Plaintiff,

-versus Civil Case No.

FOR: Damages

ANTON JIMENEZ
Defendant.
x--------------------------------------x

JUDICIAL AFFIDAVIT OF
GARDO DE LEON
(Plaintiff)

I, Gardo De Leon of legal age, single, Filipino, and residing at 8

Forbes St. Beverly Hills, Quezon City, plaintiff in this case, state
under oath as follows:

PRELIMINARY STATEMENT

The person examining me is Atty. Vincent Verzosa with address

at 7th Floor Antel Building Jade Drive Ortigas, Pasig City. The
examination is being held at the same address. I am answering his
questions fully conscious that I do so under oath and may face
criminal liability for false testimony and perjury.

This affidavit/testimony of petitioner, Gardo De Leon is being

offered to prove that Petitioner is the owner of the Toyota Vios. The
petitioner’s testimony is also offered to prove that Defendant Anton
Jimenez exhibited lack of skill and diligence in driving such vehicle
thus causing injury to plaintiff.
1. Q: Please state your name and other personal circumstances
for the record.

A: I, Gardo De Leon of legal age, single, Filipino, and

residing at 8 Forbes St. Beverly Hills, Quezon City,

2. Q: Are you the same Gardo De Leon, the petitioner in this

case?

A: Yes Sir.

3. Is the Toyota Vios, with plate number PRO 122, registered

to you?

A: Yes Sir.

4. Q. Do you know defendant Anton Jimenez?

A. No Sir. I only met Gardo De Leon when his passenger

jeepney with plate number PXH 303 collided to my Toyota
Vios, with plate number PRO 122, along University
Avenue of University of the Philippines, Diliman. on
November 10, 2019, at about 6:45 in the mornig. ORCR
of Toyota Vios is hereby attached as Annex A

5. Q: Who was driving the Toyota Vios at the time of collision

A: I am driving the Toyota Vios, Sir.

6. Q: When driving at that time, did you notice any signages

along University Avenue regarding the speed limit?

A: Yes Sir. 30Kph was the speed limit.

7. Q: Did you see any barricades along University Aveneue at

that time?

A: Yes Sir. The barricades were placed at the intersection

of Emilio Jacinto Street and University Avenue.

8. Q: Was the passenger jeepney over the speed limit at that

time of collision.

A: Yes Sir. I was driving at 30kph when I noticed a

passenger jeepney passed by my car on my right side.
9. Q: What happened when the jeepney was about to overtake
your Toyota Vios?

A: The passenger jeepney immediately turned left to avoid

the barracade placed at the intersection of Emilio Jacinto
Street and University Avenue. Thus the jeepney sideswipe
my vehicle and I went towards the island at the middle of
the street, hitting the trees.

10. Q: Did you see the driver of the passenger jeepney?

A: Yes Sir. The driver is Anton Jimenez.

11. Q: Did you sustain any injury that needed medical attention?

A: Yes Sir. I was brought to Diliman hospital by the

ambulance. And the doctors said that I sustained cuts and
bruises on my shoulders and forehead

12. Q: How much did the Diliman hospital charge you for
medical treatment?

A: My medical treatment cost me twenty thousand pesos (

P20,000 )

13. Q: Were you required by the doctors of Diliman Hospital, to

undergo monthly check ups after your treatment?

A: Yes Sir. I have monthly check ups for 3 months which

cost me ten thousand pesos ( P10,000 )

14. Q: Were you able to work during the 3 month period?

A: No Sir. I incurred loss of earnings because of the

injuries suffered from the incident. I am a businessman
and had to stop working for two months thereby losing
potential income in the amount of atleast One Hundred
Thousand Pesos (P100,000.00), representing cancelled
transactions and unrealized profits.

15. Did the accident have any effect on your mental state?

A: Yes Sir. also suffered and is still suffering mental

anguish, severe anxiety and psychological torture caused
by the incident. He has been suffering from sleepless
nights and tormented by financial expenses which could
have been avoided.
 16. Q: Finally, do you know why you are executing the
foregoing sworn statement in this case?

A: Yes, I am executing this sworn statement to be adapted

as my direct examination in this case to prove my cause/s
of action for Damages against the defendant in the above
entitled case, and this judicial affidavit be marked as
EXHIBIT “B”

IN WITNESS WHEREOF, I have hereunto set my hand this

15th day of December 2019 at Quezon City.

SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in

and for Quezon City this 15th day of Decemebr 2019. Affiant
personally came and appeared with Voter’s ID issued by the
COMELC on July 30, 2019 at Quezon City bearing his photograph
and signature, known to me as the same person who personally
signed the foregoing instrument before me and avowed under penalty
of law to the whole truth of the contents of said instrument.

Atty. Juan Reyes

Notary Public
Commission Serial No. 123456
Notary Public for Quezon City,
Until December 31, 2020
Office: No. 3 Ilagan Street,SFDM, Brgy. Paltok Q.C.
IBP Lifetime Roll No. 12345-56; 05/05/13; Quezon City
PTR No. 123457 04/13/13;
Quezon City
MCLE Compliance Cert. No.
45678; 04/04/13

Doc. No. 381

Page No. 77
Book No. _77
Series of 2019