REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR
PROVINCE OF AKLAN
REGION VI

DODING DAGA DOCKET NO. 1

Complainant, For: Reckless Imprudence
-versus- Resulting to homicide
PANDA BEAR
Kalibo, Aklan
Accused.

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COMPLAINT-AFFIDAVIT
I, Doding Daga, the undersigned of legal age, and a resident of Poblacion, Kalibo, Aklan,
as the father and in behalf of the deceased victim Jerry, hereby accuses Panda Bear of the crime
of Reckless Imprudence Resulting to Homicide, committed as follows:
1. On September 9, 2022, at about 1:00 P.M., the said accused, being then the driver of a
tricycle, was passing by Mabini st., Poblacion, Kalibo, Aklan on its way to Barangay
New Buswang while carrying passengers;

2. The accused, being then the person in-charge of the tricycle, negligently ensured the
condition of the tires before running the vehicle;

3. That as the tricycle was nearing “crossing buswang”, one of its tires blew up causing
the tricycle to turn turtle down;

4. The tricycle could have been overloaded with passengers and/or running at an
unreasonable speed which caused a mere tricycle to turn turtle down due to a mere
blowing of one of its tires;

5. And because of the terrible impact to the ground, one of its passengers, Jerry,
sustained serious damages which eventually led to the latter’s death.

6. That the bereaved parents of the deceased suffered actual and moral damages in the
amount as may be rewarded by the Honorable Court under the provisions of the New
Civil Code of the Philippines.

7. In view of the foregoing, I voluntarily executed this Complaint-Affidavit for purposes

of filing criminal charges against Panda Bear.

DODING DAGA
Affiant

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR
PROVINCE OF AKLAN
 REGION VI

LOTA REYES DOCKET NO. 1

Complainant, For: Estafa and
-versus- BP Blg. 22
NEREN ROBLES
Kalibo, Aklan
Accused.

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COMPLAINT-AFFIDAVIT

I, Lota Reyes, Filipino, of legal age, with postal address at #845 Amacio Street. Andagao,
Kalibo Aklan, after being duly sworn in to accordance with law, hereby depose and say:

That I am filing a complaint against Neren Robles for Estafa and for Violation of BP
22, who can be served with summons and notices at #324 Rizal Street. Poblacion
Kalibo Aklan.

That sometime on April 1, 2022, at my residence in Kalibo Aklan, I gave Neren

several pieces of jewelry for sale on commission basis. And we have agreed that
Neren would remit the proceeds of the sale and return the unsold items within 90
days.