I, RONALDO SANTOS y PUNZALAN, Filipino, of legal age, and presently residing in Barangay Calasag, San Ildefonso, Bulacan, after having duly sworn to in accordance with law, hereby depose and say:
1. That, on or about five oclock and twenty minutes in the afternoon (5:20 p.m.), I am driving a white L300 Mitsubishi with plate RNF 479 along Tarlac-Sta.Rosa road, vicinity of barangay Sta. Rosa Young, Zaragoza, Nueva Ecija, transversing towards east direction bound to Zaragoza town proper;
2. That, the said L300 Mitsubishi was registered under the name of Reynald Darryl G. Santos of barangay Calasag, San Ildefonso, Bulacan as can be seen on the attached Official Receipt/Certificate of Registration (Annex A);
3. That, I am a holder of a Professional Drivers License (Annex B) with number CO7-90-056285 which will expire on July 22, 2016, and which is valid and existing during the date and time material to this case;
4. That, the said L300 Mitsubishi was involved in a Traffic Vehicular Accident as per Police Report (Annex C) prepared by PO1 Denver M. Diaz on March 30, 2014, as vehicular 2 (V2) and involving two (2) other vehicles;
5. That, on that date and time material to this case, I was driving a white L300 Mitsubishi with plate RNF 479, at a speed of twenty (20) to twenty Page 2 of 4
five (25) kilometers per hour (kph), maintaining a four (4) to five (5) meters away from the vehicle in my front;
6. That, as I was looking at the vehicle in front of me, I noticed that the said vehicle suddenly stopped, which in that case, I immediately stepped on my break;
7. That, I felt a sudden motion that struck on the back portion of the L300 Mitsubishi that I am driving;
8. That, however hard I stepped on the break, the rear front of the vehicle which I was driving hit the rear back portion of the vehicle in my front due to the force brought by the impact of the collision that hits the rear back of the vehicle that I was driving;
9. Attached as Annex D-1&2 are pictures which shows that there is indeed three (3) vehicles involved in this traffic vehicular accident, which are the blue Nissan urvan, white L300 Mitsubishi and silver gray Kia Picanto;
10. Annex E-1&2 are also pictures which shows that the front portion of the L300 Mitsuishi with plate RNF 479 hits the back portion of the Nissan Urvan with plate CST 221, which incurred an estimated amount of sixty four thousand two hundred pesos (P64,200.00) (Annex F), which is now a basis why I am a respondent in NPS No.: III-09-INV-14D-00943 for RECKLESS IMPRUDENCE RESULTING IN DAMAGE TO PROPERTY (Annex G);
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11. That, due to the said vehicular accident, the L300 Mitsubishi that I drove incurred damage with an estimate of fifty thousand two hundred eighty four and 24/100 pesos (P50,284.24) (Annex H);
12. That, the resulting damage to the Nissan Urvan driven by Mr. Rommel Macaburas y Alberto and to the L300 Mitsubishi which I drove are all attributable to the negligence of the third vehicle which is the Kia Piacanto with plate RMM 786 driven by Errol Enriquez II y Mandap;
13. That, the proximate cause of the collision is the reckless driving of the Kia Picanto driver in the name of Erro Enriquez II y Mandap which causes the damage to the L300 Mitsubishi that I drove and which causes further damage to the Nissan Urvan with plate CST 221;
14. Annex 9-A&B are pictures which shows that the Kia Picanto hits the back portion of the L300 Mitsubishi which in turn causes the latter vehicle to bump the Nissan Urvan which was situated in front;
15. That, the L300 Mitsubishi would not have hit the back porion of the Nissan Urvan if not for the force of impact coming for the bumping of the Kia Picanto at the back of the L300 Mitsubishi;
16. That, I am executing this affidavit to attest to the truth of the foregoing and for filing a complaint against MR. ERROL ENRIQUEZ II y MANDAP for RECKLESS IMPRUDENCE RESULTING IN DAMAGE TO PROPERTY;
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IN WITNESS WHEREOF, I have hereunto affixed my signature this 6 th
day of May, 2014, in Cabanatuan City, Nueva Ecija.
RONALDO SANTOS Affiant
SUBSCRIBED and SWORN to before me this 6 th day of May, 2014, in Cabanatuan City, Nueva Ecija. I hereby certify that I have personally examined the above-named affiant and that I am satisfied that the foregoing statements were given by him voluntarily and of his own free will. ADMINISTERING OFFICER