REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

BRANCH 31
Negros Oriental

JUAN DOMINGO
Plaintiffs,
Civil Case No. 1234567
-versus- For: Complaint for Damages
RENATO SANTOS AND PEDRO CRUZ
Defendants.
x-------------------------------------------------x

COMPLAINT

COMES NOW, the plaintiff through the undersigned counsel and to

this Honorable Court, respectfully alleged that:
1. The Plaintiff Juan Domingo is of legal age, widower, a resident of
Purok Banica, Valencia, Negros Oriental;
2. That he may be served with all correspondence and court processes in
the said residence;
3. That, Pedro Cruz is the owner of ABC Bus Lines;
4. That, Renato Santos is a regular employee of ABC Bus Lines;
5. That, on 27 January 2021, Maria Domingo, the wife of herein
Plaintiff.

First Cause of Action

6. That, on 27 January 2021, Domingo and Mark Dela Cruz, a co-

worker, were heading home driving a motorcycle vehicle from
Dumaguete City. While traversing Dumaguete National Highway,
they had head on collision with a public transportation bus at
Dumaguete National Highway. The said bus was driven by Renato
Santos.

Second Cause of Action

7. That, on the same date, due to the severity of the collision, Maria died
on the spot. While Dela Cruz died while being rushed to the hospital.
SUMMARY OF DOCUMENTARY EVIDENCE AND WITNESSES

PARTICULARS PURPOSE
1. Certificate of Employment of Maria Domingo- To prove that Maria Domingo was
employed and was earning that entitles the plaintiff for actual and
compensatory damages

2. Judicial Affidavit of Jim Karya- To prove that Renato Santos was negligent 

3. Statement of Accounts for Medical and Funeral Expenses- To prove the medical
and funeral expenses incurred   

4. Judicial Affidavit of SPO1 Minerva Seba- To inform the honorable court of the
fateful incident 
5. Closed-Circuit Television footage

PRAYER
WHEREFORE, it is respectfully prayed that judgment be rendered in
favor of plaintiff and against defendant for the sum of:
a. One Hundred Thousand Pesos (Php 100, 000) as Actual
Damages;
b. Fifty Thousand Pesos (Php 50, 000) as Moral Damages;
c. Fifty Thousand Pesos (Php 50, 000) as Exemplary Damages;
and
d. Fifty Thousand Pesos (Php 50, 000) as Attorney’s Fees

Such other relief as may be just and equitable under the premises are
likewise prayed for.

Dumaguete City, Philippines, April 19, 2021.

ATTY. CLAUDINE S. UANAN

Counsel for the Plaintiff
Unit 1, X Building, Dumaguete City
IBP No. 12345; 10/01/11
PTR No. 12345; 01/11/12
Roll No. 654321; 05/11/11
MCLE No. I- 09/01/20
MCLE No. II- 12/12/20

The undersigned counsel certifies the following:

1. That, I have read and understood the foregoing averments by the
the plaintiff;
2. That, to the best of my knowledge, information, and belief, formed
after an inquiry reasonable under the circumstances:
a. that the Complaint is not being presented for any improper
purpose, such as to harass, cause unnecessary delay, or
needlessly increase the cost of litigation;
b. That the claims, defenses, and other legal contentions are
warranted by existing law or jurisprudence, or by a
 nonfrivolous argument for extending, modifying, or
reversing existing jurisprudence;
c. The factual contentions have evidentiary support or, if
specifically so identified, will likely have evidentiary
support after availment of the modes of discovery under
these rules; and
d. The denials of factual contentions are warranted on the
evidence or, if specifically so identified, are reasonably
based on belief or a lack of information.

CLAUDINE S. UANAN

VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, Juan Domingo, of legal age and a resident of Purok Banica

Valencia, Negros Oriental, under oath declare that:
1. I am the defendant in the above-captioned case;
2. I have caused the preparation of the foregoing Answer; and
3. I have read and understood the contents thereof, and the same are
true and correct to my personal knowledge.
4. I have not earlier commenced a similar action against the
defendant for the same cause of action with any other court,
tribunal or quasi-judicial agency;
5. No such action or proceeding is pending with any other court,
tribunal or quasi-judicial agency;
6. If I should learn that a similar action or proceeding has been filed
or is pending before any other court, tribunal or quasi-judicial
agency, I hereby undertake to notify this Honorable Court within
five (5) days from such notice;

JUAN DOMINGO

SUBSCRIBED AND SWORN to before me, this 19 th of April 2021,

by Juan Domingo who exhibited to me his Driver’s License No. DL-12345
issued at Quezon City, Philippines on January 2020. That the above
 Notary Public

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