Professional Documents
Culture Documents
- versus
COMPLAINT
COMES NOW, plaintiff, Chong Go, by counsel, and unto this
Honorable Court, most respectfully avers THAT:
1. Plaintiff is a Filipino, of legal age, married, and residing at Yumang
St., General Santos City, where he may be served with summons,
papers and other process of this Honorable Court HIGOT Law
Firm, Suite 704, Pardo Bldg., Bingka Street, Gensan City.
2. Plaintiff, upon going to the work, received a phone call from his wife
telling that she went away to another man. As a result of shock, he
ran over a restaurant and caused damages to the property as well
as injured three customers.
3. The plaintiff is hereby contends that the defendant is liable for the
damages he incurred.
4. The consecutive circumstances that happened to the plaintiff is at
the fault of the defendant, thereby, causing him to be anguished,
sued, and indemnified.
5. Hence, the petition seeks that the defendant be made liable to pay
for damages of restaurant and the of customers, in the amount
equivalent
to
FIVE
HUNDRED
THROUSAND
PESOS
(P
500,000.00).
6. Due to the sudden separation of his wife, he 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 FIVE PERCENT (25%) of the total
amount to be adjudged in favor of plaintiffs, and the costs of this
suit.
PRAYER
WHEREFORE, the above premises considered, it is
respectfully prayed of this Honorable Court after hearing on the
merits, that:
a. Defendants be made liable to pay for damages for
death
in
the
amount
of
THREE
HUNDRED
THROUSAND PESOS.
b. Defendants be ordered to pay moral damages in the
amount of TWO HUNDRED THOUSAND PESOS (Php
200,000.00);
c. Defendants be ordered to pay attorneys fees in an
amount equivalent to TWENTY FIVE PERCENT (25%)
of the total amount to be adjudged in favor of plaintiffs;
d. Defendants be made liable for all the payments he
incurred to pay the costs of this suit.
ACKNOWLEDGEMENT
Received from Tonying C. Lato, his Cimarron Jeepney
with Plate No. LXX-349, for repair and other necessary fixing.
The said acceptance is with the consequent assurance that
we will be responsible for any and all incidents which may
occur while the said vehicle is in our custody.
Done this 29th day of December, 2010.
Marco Lava
Owner and Manager
Ultra
Speed
Machine Shop
and As Metal Products