Republic of the Philippines

NATIONAL POLICE COMMISSION

PHILIPPINE NATIONAL POLICE
NAGA CITY POLICE OFFICE
POLICE STATION 2
Brgy. Peñafrancia, Naga City

City Prosecution Office September __,

2023 City of Naga

Sir/Madam.

I have the honor to send you here with a case of RECKLESS IMPRUDENCE
RESULTING in DAMAGE to PROPERTY wherein the accused is;

AT LARGE

RONALDO ALVAREZ y SANCHEZ, 43 years old, unemployed, H/S graduate, a resident of

Zone 3, Sanchez Compound, Brgy., Pangpang (Pob), Canaman, Camarines Sur, holder of DL No.
E04-16-000126, with Cp No. 09924799417;

PIECES OF EVIDENCE:

1. Complaint-Affidavit of JOWENA MAY AYEN y PAGAO – Complaining witness

2. Investigation Report
3. Photocopy of Official Receipt and Certificate of Registration (V1 and V2)
4. Photocopy of Driver’s License (D1 and D2)
5. Written Agreement of D1 and D2
6. Estimated Job Quotation
7. Blotter Excerpt
8. Pictures

PCpl Tipones JC of TEU & PS3, NCPO-Investigator On Case

Very truly yours,

Jay T Delos Santos

Polices Staff Sergeant
Senior Traffic Investigator
 ENDORSEMENT
February __, 2023

The City Prosecutor

City Prosecution Office
City of Naga

Sir:

My I file a formal complaint against the person of RONALDO ALVAREZ y SANCHEZ,

43 years old, unemployed, H/S graduate, a resident of Zone 3, Sanchez Compound, Brgy., Pangpang
(Pob), Canaman, Camarines Sur, holder of DL No. E04-16-000126, with Cp No. 09924799417 for a
case of RECKLESS IMPRUDENCE RESULTING in DAMAGE to PROPERTY committed
against the law on or about 5:22 p.m. of July 20, 2023, along Peñafrancia Avenue, Peñafrancia
Naga City, Philippines. The facts and circumstances are all contained in my sworn
statements.

Trusting that this will be given preferential attention.

Very truly yours,

JOWENA MAY AYEN y PAGAO

VERIFICATION

I, JULIE BENITEZ y ARTETA

Under oath hereby declare; that I am the complainant of this particular case; that I
have caused the preparation of this letter complaint and that I have read the entire allegation
therein contained and the same are true and correct to the best of my knowledge and
consent.

JOWENA MAY AYEN y PAGAO

Affiant

SUBSCRIBED AND SWORN to me before this ___ day of September 2023, in

the City of Naga, Philippines and I further certify that I have personally examined the affiant
and that I am fully satisfied that he voluntarily executed the foregoing instrument and that
he fully understands his statements contained therein.
Republic of the Philipphines)
City of Naga ) ss

COMPLAINT-AFFIDAVIT

I, JOWENA MAY AYEN y PAGAO, 38 years old, married, a resident of B5, L3, Ph1,
Mariners Village, Santa Lucia Magarao, Camarines Sur, holder of Non-Professional Driver’s
License No. E04-10-003872, with Cp No. 09173379282, after having sworn in accordance
with the laws, hereby depose and say;

That, I will file a case against RONALDO ALVAREZ y SANCHEZ, 43 years old,
unemployed, H/S graduate, a resident of Zone 3, Sanchez Compound, Brgy.,
Pangpang (Pob), Canaman, Camarines Sur, holder of DL No. E04-16-000126, with Cp
No. 09924799417, for a case of RECKLESS IMPRUDENCE RESULTING IN DAMAGE TO
PROPERTY;

That, I and my husband, Basilio T. Ayen Jr., were legitimate registered owners of a
white Suzuki Dzire GL AMT Sedan bearing Plate No. EAB 8025 was registered under
the name of my husband, Basilio T. Ayen Jr., which we acquired sometimes in the year
2018.

That, at approximately 5:22 p.m. of July 20, 2023, while I was driving the aforesaid
vehicle and was traversing along Peñafrancia Avenue, Naga City, facing Brgy. San
Felipe: I was involved in a vehicular incident. Upon reaching the intersection of
Magsaysay Avenue and Peñafrancia Avenue, I stopped since the traffic lights thereat
were about to turn red, and then I was shocked when the rear portion of my vehicle was
bumped by a black Honda CCG125WHJ with a sidecar (private) bearing Plate No.
755EEH, which later I found out was registered to the driver identified as RONALDO S
ALVAREZ;

That, after the incident, police officers arrived and asked for our driver's license. I
noticed that the incident resulted in damage to my vehicle at the rear portion and also
to the tricycle at the front portion, while the passenger had an injury. Later on, an
investigator arrived and conducted an investigation and some questioning of us drivers,
then he accompanied us to Police Station 3, Brgy. Peňafrancia, Naga City. Then the
passenger was brought to the hospital.

That, after the passenger was treated in the Hospital, RONALDO S ALVAREZ the
tricycle driver returned to station, then the investigator explained to us the incident. The
former and his common law wife which I indentified as GINA CURVA Y CORTEZANO,
legal age, self-employed, a resident of Zone 5, Kilometer 6, Brgy. Pacol, Naga City
which he was acknowledging the tricycle driver fault and was apologizing, accordingly
they will shoulder the cost of damage to my driven vehicle. Which later we come up into
an agreement, we signed an agreement that the tricycle driver will pay the cost of
damage my driven vehicle which is the first payment was on August 30, 2023.

That, after the passenger whom I identified as GINA CURVA y CORTEZANO, legal age, self-
employed, and resident of Zone 5, Kilometer 6, Brgy. Pacol, Naga City, was treated in the hospital
together RONALDO S. ALVAREZ, the tricycle driver, they both returned to Police Station 3. The
investigator explained to us the incident. The formers (Alvarez and Curva) acknowledged it was their
fault and apologized to me; accordingly, they will shoulder the cost of the damage to my driven
vehicle, and he (Alvarez) is giving his other motorcycle as collateral while he is not yet fully paid to
me, which I refused sice accordingly it was not registered under his name. Later, we came to an
agreement: we signed an agreement that the tricycle driver would pay the cost of repairing my driven
vehicle, and the first payment was on August 30, 2023.
 That, Meanwhile, this is my statement; I don't want to add or subtract anything from it;
if I do, it will only be in court. 

JOWENA MAY AYEN y PAGAO

affiant

SUBSCRIBED AND SWORN to me before this ___ day of February 2023, in the City of
Naga, Philippines and I further certify that I have personally examined the affiant and that I
am fully satisfied that he voluntarily executed the foregoing instrument and that he fully
understands his statements contained therein.

D2-Driver’s License and V2-Vehicle Information