Republic of the Philippines )

Quezon City )s.s

COMPLAINT-AFFIDAVIT

I, HENRY LAO, of legal age, Filipino citizen, ____________,

after having duly sworn to in accordance with law do hereby depose and
state that:

1. I am formally charging Andrew Tan, the Chairman of the Board,

President and Chief Executive Officer of Megaworld Coporation with
business address at No. 330 World Centre Building Sen. Gil Puyat
Avenue, Makati City for the crime of Reckless Negligence Resulting in
Serious Physical injury penalized under Art. 365 of the Revised Penal
Code, as amended by Republic Act No. 1790, committed as follows:

a. On 17 August 2015 at around 2:00 oclock in the afternoon, I

decided to walk around Eastwood Mall in Libis Quezon City;

b. That while I was walking I chanced upon an open elevated

platform and decided to walk on it. From where I was, I saw
a bridge from the side end and decided to take a look. I
walked towards the other end of the elevated platform and as
I was about to descend therefrom, there was no step. Copy of
the photocopy of the platform is hereby attached as Annex A;

c. I fell down and twisted my left leg. I fell so hard to the

ground that I felt intense pain. I could not stand up so much
so that I was assisted by the guards and placed me in a
wheelchair. I was later brought to the medical clinic of
Eastwood Mall;

d. The nurse at the said clinic applied a cold patch to the injury
of my broken leg for several minutes after which the injured
leg was bandaged. I was advised by the nurse to apply cold
patch upon reaching home;

e. Little did I know that this would make my injury far worse.
Soon after, there was an inflammation and terrible blisters
that start to appear around the injured area. I was taken to
Delos Santos Medical Center for medication. My leg was
placed in a cement cast for about two (2) weeks as the initial
diagnosis was severe sprain;

f. After which the pain persisted and I was taken to Marikina

Orthopedic Specialty Clinic where I was diagnosed to have
 FRACTURED LEFT LEG and was again put to a cast for
several months. The said fractured leg seemed to have healed
but the pain persisted until this day. Copy of the Medical
Certificate is hereby attached as Annex B;

g. As a result of the injury, I am in permanent limp denying me

of my usual daily routine of walking, light jogging and
exercise;

h. This incident was brought to your companys attention.

Unfortunately your company could only offer a free overnight
stay and a lunch buffet;

i. The expenses for medical treatment for my sustained injuries

amounted to One Hundred Thirteen Thousand Seven
Hundred One & 89/110 (PhP 113,701.89). This amount is
exclusive of the sleepless nights and mental anguish which I
suffered by reason of your companys gross negligence and its
unjustified refusal to defray my medical expenses. Copy of
the receipt of my medical expenses are hereby attached as
Annex C;

2. That I am filing this Complaint-Affidavit to attest to the truth of the

foregoing and to charge respondent for Reckless Negligence resulting in
Serious Physical Injury of the Revised Penal Code, as amended by
Republic Act No. 1790.

IN WITNESS WHEREOF, I have hereunto set my hand this __ th

day of March, 2017 in Quezon City.

HENRY LAO
Complainant-Affiant

SUBSCRIBED AND SWORN to me before this __th day of

March, 2017 at Quezon City. I have personally examined the affiant and I
am satisfied that he voluntarily executed and understood his Complaint-
Affidavit.

Assistant City Prosecutor