Republic of the Philippines

MUNICIPAL TRIAL COURT

FIRST JUDICIAL REGION
Branch _

STEVE S. GAANO,
Plaintiff,
CIVIL CASE No. 90782
-versus-
FOR: Damages for Physical
Injuries, Moral damages
and Attorney’s Fees.
HECTOR V. DORIA,
Defendant.
x---------------------------------------x

COMPLAINT

Plaintiff, through undersigned counsel, and unto this Honorable Court

alleges:

1. That the plaintiff is single, Filipino citizen and residing at No. 111
Middle Quirino Hill, Baguio City, where he may be served with
court processes, motions ad decisions while the defendant is a
Filipino citizen, single and residing at No. 08 Trancoville, Baguio
City where he may be served with summons and court processes;

2. That on or about 7:00 o’clock in the evening defendant due to

jealousy to plaintiff, stabbed the latter using a kitchen knife and the
defendant obtained two stabs at his stomach;

3. That the plaintiff was able to run and defendant did not further go
after him;

4. That the plaintiff was accompanied by his mother and sister to the
Baguio General Hospital the following day for medication and
incurred more or less the total amount of SEVENTY-FIVE
THOUSAND PESOS (PHP75,000.00) as evidenced by a the
statement of bills attached hereto as ANNEXES “A-1” and “A-2”;

5. As a result of the injuries sustained by defendant, his family is in

financial difficulties because they depend on him as a sole wage
earner in the family, because his parents were both unemployed.
Hence, defendant must be made to pay for damages for the
hospitalization bills and other medication costs incurred in the
 amount of ONE HUNDRED THROUSAND PESOS (P
100,000.00).

6. Due to the physical injuries sustained by plaintiff, his family

suffered mental anguish and serious anxiety;

7. 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 TWENTY THOUSAND PESOS
(PHP20,000.00), and the costs of this suit.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable Court

that:

a. Defendant be ordered to pay for damages for the medication costs

of the physical injuries sustained by plaintiff in the amount of ONE
HUNDRED THOUSAND PESOS (PHP100,000.00);

b. Defendant be ordered to pay moral damages in the amount of FIFTY

THOUSAND PESOS (Php 50,000.00);

c. Defendants be ordered to pay attorney’s fees in an amount

equivalent to TWENTY THOUSAND PESOS (PHP20,000.00);
and

d. Defendants be ordered to pay the costs of this suit.

Other reliefs just and equitable under the premises are likewise
prayed for.

Respectfully submitted this 7th day of October 2019, done in the City
of Baguio, Philippines.

ATTY. DANIEL D. MAABAK

Counsel for Plaintiff
2/F Kalayaan Building
Kisad Road, Baguio City
(074) 304-3675/ 09057037608
PTR No. 2065108; 1-15-2019/Baguio City
Roll No. 65108; 6-10-2012/Baguio City
IBP Membership No. 2029338, 1-15-2019
Baguio-Benguet
VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

REPUBLIC OF THE PHILIPPINES)

DONE IN THE CITY OF BAGUIO ) S.S.

I, STEVE S. GAANO, of legal age, single, Filipino Citizen and a

resident of No. 111 Lower Quirino Hill, Baguio City, Philippines, after having
been sworn to in accordance with law, do hereby depose and say:
That I caused the preparation of the complaint in the above-entitled case
which I read and understood the contents thereof which are true and correct
to my own knowledge;
That I have not filed any similar action to the Supreme Court, Court of
Appeals or any other Court, Tribunal or Agency;
That if I should thereafter learn that a similar action or proceeding has
been filed in the Supreme Court, Court of Appeals or any other Tribunal or
Agency, I undertake to report the fact within five (5) days thereafter to this
Honorable Court.
IN WITNESS WHEREOF, I have hereunto affix my signature this 7th
day of October 2019, in the City of Baguio, Philippines.

STEVE S. GAANO
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio this

7th day of October 2019 by STEVE S. GAANO, who has satisfactorily proven
her identity to me through his Tax Identification No. 219-102-189 issued on
April 11, 2015 at Baguio City, that he is the same person who personally
signed the foregoing complaint before me and acknowledged that he executed
the same.

Doc. No.: __________;

Page No.: __________;
Book No.: __________;
Series of: __________;