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AFFIDAVIT-COMPLAINT I Amador Bulan, of legal age, and a resident of 143 Sandawa Road, Davao City after having been sworn in accordance with law hereby depose and say: 1. That I am the owner of a KB Hino Cargo Truck with plate no. LST 530 which is primarily use in the regular business of general trucking services, and the employer of Rolando Suizo, the truck driver and Rolando Katigbak, the truck helper ; 2. That on October 26, 2009 while my driver Rolando was driving back to our garage from a prior delivery in the South and upon approaching the intersection of Sandawa Road and Mc Arthur Highway along Matina Davao City, the speeding bus with body no. 1357 which we later knew was driven by MR. BENJAMIN BIGAT who resides at 26 Ecoland Subdivision, smashed hit the left back portion of our truck bearing plate no. LST 530 instantly killing our truck helper ROLANDO KATIGBAK and causing damage to the truck, copy of traffic accident report, repair cost estimate, death certificate and the report of attending physician, are hereto attached for reference; 3. That the said bus with body no. 1357 is owned by DAVAO RABBIT BUS LINES; 4. That BIGAT drove his vehicle at a very high speed and while encroaching the opposite lane he did not bother to slacken or reduce his speed or even stopped when it approached the intersection; 5. That bystanders who were at the scene immediately tried to rescue and give aid to our truck helper by bringing him to the nearest hospital but he eventually passed away due to the severity of his injury; 6. That BIGAT was violating the traffic rules when he encroached the opposite lane and failed to stop or reduce his speed considering that it was a cross thru road, and was driving the bus recklessly when he smashed hit our truck; 7. That MARCELINO PADAYOGDOG witnessed the incident and caused the recording of the same
at the proper police authorities, a copy together with his affidavit of witness are hereto attached for reference;

8. That I am executing this affidavit to attest to the truth of the foregoing facts and to apprise the City Prosecutor of the same, for the purpose of prosecuting BENJAMIN BIGAT of the crime of reckless imprudence resulting in homicide and damage to property as defined under the Revised Penal Code of the Philippines as amended and the applicable special laws;

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IN WITNESS WHEREOF, I have hereunto set my hands this 01st day of March 2010 at Davao City, Philippines


SUBSCRIBED AND SWORN TO before me this 01st day of March in the City of Davao, Philippines personally appeared the affiant and I hereby Certify that I personally examined him and I am satisfied that he personally caused the execution of this affidavit, has read the same and understood its contents.

EDWIN L. DIEZ Prosecutor I (Asst. City Prosecutor)