COMPLAINT

Plaintiff, by counsel and to this Honorable Court, respectfully states that:

1. Plaintiff Alfredo C. Bayudan is of legal age, Filipino, single, and a resident of 30C San
Vicente Ferrer St, San Antonio Valley Paranaque, Philippines. For purposes of this action,
plaintiff may be served with all orders, notices, and other processes of this Honorable
Court through the office address of the undersigned counsel indicated below;
2. Defendant Western Guaranty Corporation, and may be served with summons and other
processes of this Honorable Court at his last known address at Suite 508 BPI Office
Condominium Plaza Cervantes, Binondo, Manila, Philippines;
3. Sometime on October 28, 2015, 5:30 pm, based on the Traffic Accident Investigation
Report of the Manila Police District, Special Investigation and Detection Branch the
plaintiffs vehicle (ISUZU CROSSWIND) momentarily parked along the stretch of
Alvarez Street, corner Severino Reyes in its left side was suddenly hit by the left rear
end of a (TOYOTA TAMARAW). The impact resulted in unascertained amount of
damage to plaintiffs car but created a dent on the drivers side. No person was injured.
4. Plaintiff first made the demand to defendant to pay for the insurance liability on
November 30, 2015, on the same day plaintiff sent via electronic mail a quotation of the
Job Estimate for the Repair of plaintiffs vehicle. The amout of said repairs amounts to
P16, 500.00
5. As of December 11, 2015, Defendant still has not complied with the demand of plaintiff
for damages as insurer.
6. Despite Plaintiff's repeated demands, verbal, Defendant failed, neglected and refused, and
continues to fail and refuse to pay and to settle the said damages, without just and valid
grounds, to the continued damage and prejudice of Plaintiff;
7. A true and faithful machine reproduction of the Plaintiff's demand letter to Defendant
dated _____________ is hereto attached as Annex "B";
8. Consequently, Plaintiff was constrained to engage the services of counsel to whom it

obligated itself to pay as Attorney's Fees the amount equivalent to _____________

(______%) percent of the total amount due from Defendant to Plaintiff.
PRAYER
WHEREFORE, after due notice and hearing, Plaintiff respectfully prays that judgment be
rendered against the Defendant as follows:
1. Ordering the Defendant to pay Plaintiff the sums of:
a.

The amount of Sixteen thousand five hundred pesos only (P16, 500.00),
representing Defendant' liability as insurer,

b.

_____________ (_____%) percent of the total amount due as Attorney's Fees

plus Appearance Fee at the rate of P__________ per court hearing /
conference;

c.

_____________ (_____%) percent of the total amount due as Collection

Charges / Liquidated Damages;

d.

The costs of suit.

2. Plaintiff respectfully prays for such other reliefs as may be just and equitable in the
premises.
Date: December 16, 2015, Philippines,

(COUNSEL)

(VERIFICATION)

(CERTIFICATION OF NON-FORUM SHOPPING)