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PIA CHUA,
Plaintiff,
-versus-
COMPLAINT
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4. Plaintiff is a licensed vehicle driver with a valid Philippine driver’s
license. Attached hereto is an official copy of her driver’s license
referred to as ANNEX “A”;
9. At the time that Plaintiff was driving, El Grande Avenue did not
have any working street lamps and the road was dark (ANNEX
“D”);
12. Plaintiff fell into the open drainage construction and due to the
said accident, Plaintiff suffered multiple contusions and retained
visible lacerations including one on low distal forehead;
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13. Plaintiff also suffered from severe back pain, and neck strain
causing her to wear a neck brace for two weeks as evidenced by the
medical report form referred to as ANNEX “E”;
14. Plaintiff suffered actual damages for medical expenses in the sum
of TEN THOUSAND SEVEN HUNDRED NINETY-ONE PESOS
(Php 10,791.00). Attached is the Hospital Bill referred to as
ANNEX “F”;
15. Plaintiff also suffered also mental anguish, serious anxiety, and
moral shock for which she must be recompensed moral damages
in the sum of FIFTY THOUSAND PESOS (P50,000.00);
16. The Montero Sport owned and driven by Plaintiff was severely
damaged and requires extensive repairs estimated at ONE
HUNDRED NINE THOUSAND SIX HUNDRED THIRTY-SIX
PESOS AND EIGHTY CENTAVOS (P109,636.80) as manifested in
the Work Order referred to as ANNEX “G”;
PRAYER
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With legal interest from the date of filing this suit, plus other costs
of suit.
By:
COPY FURNISHED:
(By Registered Mail/ Courier)
CITY OF PARANAQUE
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VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING
Pia Chua
Affiant
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Atty. Micah Celine Carpio
Notary Public
PTR No. 12309885, Makati City, 1/5/20
IBP OR No. 1294880, Makati City, 1/5/20
Attorney’s Roll No. 91564
MCLE Compliance Certificate No. IV-554145, Makati City,
1/5/20