A F F I D A V I T

I, Mario S. Villanueva, of legal age, widower, a Filipino citizen and residing

with postal address at Barangay Gun-ob, Lapu-Lapu City, after being sworn to
according to law, do hereby depose and state:

That a Toyota Corolla Sedan with plate no. GPT 490 is registered in the
name of Pablo R. Bacaltos, of #74 Barangay Pajo, Lapu-Lapu City, as per Certificate
of Registration No.CR 74167694 and Official Receipt No. 1788500022 dated
October 24, 2019 ,hereto attached as Annex “A” & “B”, respectively;

That the aforementioned vehicle was sold to me by Pablo R. Bacaltos on

May 15, 2015, as per Deed of Absolute Sale, hereto attached as Annex “C”;

That on August 3, 2019 at about 3:37 o’clock p.m., I was riding the said
motor vehicle driven by Mr. Roy Delarita Genolos and we were on our way to
Cebu City coming from Humay-humay Road, Barangay Gun-ob, Lapulapu City;

That while we stopped as we were waiting for the Green Light, we were
both surprised when the car we were riding in was hit and bumped by a car which
was travelling behind us;

That the car which bumped us was a Mitsubishi Mirage G4 GLS Sedan with
plate No. AEC 8002 driven by a Mr. Karrem R. Carayo residing at 53 Old Bridge,
Barangay Pajo, Lapu-Lapu City;

That because of the incident, my car sustained damages in the rear bumper
and it was cracked and deformed and caused anxiety and stress to the both
myself and the driver;

That the driver of the offending car admitted drinking Red Horse during the
investigation, and he is a holder of NPDL No. G061004793, which expired on
November 2, 2018;

That a Certification of the entry in the Police Blotter is hereto attached

where the investigator stated the facts of the incident, marked as Annex “D”;

That pictures of the car showing the position of the two vehicles and the
damage incurred to my car are also attached here as “Annex “E” and “F”;

That the estimated amount of repairs done by JoyRide is P18,000.00, the

computation is hereto attached as Annex “G”;
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That the driver of the offending vehicle, the respondent in this particular
case has promised to shoulder the expenses but he kept on asking for time to
have the money to pay, but has not done so even until the present time;

That while waiting for the fulfillment of the promise, I had to continue using
the car as I have no other means of transport, and this continued use caused the
sagging rear bumper to fall to the ground, resulting in the inconvenience and
embarrassment of Mr. Mario S. Villanueva;

That a demand letter has been sent to Moses Karren R. Carayo, but no
response has been received nor was there a word received from him; thus, he has
no intention to fulfill his promise of payment, a copy is hereto attached as Annex
“H”;

Further Affiant Sayeth none.

In Witness Whereof, I have hereunto affixed my signature on this 10 day of

December, 2019, in Lapu-Lapu City, Philippines.

MARIO S. VILLANUEVA
Affiant

Republic of the Philippines)

City of Lapu-Lapu )S.S.

Subscribed and Sworn to before me on the date and place first mentioned,
affiant exhibited to he his Identification Card.

Doc. No. .
Page No.
Book No. .
Series of 2019.