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COMPLAINT
Plaintiff Davao Rabbit Bus Line, duly assisted by counsel and
unto this Honorable Court, most respectfully files this complaint and
ever THAT:
THE PARTIES
Page 1 - Complaint
contained in a resolution passed for the purpose. (See attached
Secretarys Certificate as Annex A and A-1).
CAUSE OF ACTION
PRAYER
WHEREFORE, PREMISES CONSIDERED, it is most
respectfully prayed of this Honorable Court, after hearing and trial on
the merits, that judgment be rendered in favor of the plaintiff as
follows:
Plaintiff and counsel pray for such other relief consistent with
justice and equity under the premises.
Page 4 - Complaint
Represented by:
EDILBERTO CABILLES
General Manager
Assisted by:
By:
ROBELEN-ANN G. CALLANTA
PTR No. 898651/01-25-17/Davao City
IBP Life Member Roll No. 023911
Roll of Attorneys No. 68991
MCLE Certificate of Compliance No. V-112211
Issued on April 28, 2015, Pasig City
JOHARI CASAN
PTR No. 01-14-17/Davao City
IBP Life Member Roll No. 023712
Roll of Attorneys No. 69963
MCLE Certificate of Compliance No. V-121685
Issued on May 5, 2015, Pasig City
Page 5 - Complaint
ALONA SUZELL RUYERAS
PTR No. 01-18-17/Davao City
IBP Life Member Roll No. 022954
Roll of Attorneys No. 67432
MCLE Certificate of Compliance No. V-124011
Issued on April 24, 2015, Pasig City
Page 6 - Complaint
REPUBLIC OF THE PHILIPPINES)
DAVAO CITY )S.S.
x---------------------------------------------x
EDILBERTO CABILLES
Affiant
Page 7 - Complaint
2017, at Davao City, Philippines bearing EdilbertoCabilles
photograph and signature as competent proof of identity.
Davao City,
MARIA
Philippines
NOTARY
AYRA
Roll No. 67890
PUBLIC
CELINA
S.
BATACA
N
Page 8 - Complaint
ANNEX A
SECRETARYS CERTIFICATE
MAX MONGOL
Corporate Secretary
Page 9 - Complaint
SUBSCRIBED AND SWORN TObefore me this 15th day of January 2017
at Davao City, Philippines. The affiant presented to me his valid Drivers License
with No. 12341341 issued on June 21, 2016 and to expire on June 25, 2019
bearing his photo and signature as competent proof of his identity.
Davao City,
MARIAPhilippines
NOTARY
PUBLIC
CELINA
S.
BATACA
N
Page 10 - Complaint
ANNEX B
Traffic Accident Report
c/o Johari
Page 11 - Complaint
ANNEX C
Receipt
OFFICIAL RECEIPT
Description:
REPAIR OF BUS
Page 12 - Complaint
ANNEX D
November 10 Demand Letter
Sir,
In line with the collision that occurred last October 26, 2016 which resulted to our Bus No. 1357 with
plate no. 246 to be severely damaged, we would like to demand for the reimbursement of repair
expenses amounting to P200,000. Attached herewith is the Traffic Accident Report which proves that
the driver of your truck was reckless in handling your vehicle which resulted to the unfortunate
accident. Moreover, the receipt for the repair of the said bus is also attached in this letter.
Please comply with your legal obligations. Failure to do so would compel us to take the necessary
actions to assert our claim.
Sincerely yours,
J.D. Cruz
Atty. Juan Dela Cruz
Page 13 - Complaint
ANNEX E
December 5 Demand Letter
December 5, 2016
Sir,
We would like to follow-up our demand which we first made through a letter sent last November 10,
2016 as to our demand for the reimbursement of repair expenses amounting to P200,000.
Attached herewith is a copy of our November 10 demand letter and its pertinent attachments for
your reference.
Once again, we implore that you comply with your legal obligations. Failure to do so would compel
us to take the necessary actions to assert our claim.
Sincerely yours,
J.D. Cruz
Atty. Juan Dela Cruz
Page 14 - Complaint
ANNEX F
Letter to Insurance Company
In line with the collision that occurred last October 26, 2016 between our bus and the truck owned
by one Amador Bulan which resulted to our Bus No. 1357 with plate no. 246 to be severely damaged,
we would like to demand for the reimbursement of repair expenses amounting to P200,000.
Attached herewith is the Traffic Accident Report and the receipt for the repair of the said bus for
your reference.
Sincerely yours,
J.D. Cruz
Atty. Juan Dela Cruz
Page 15 - Complaint
ANNEX G
Denial Letter of Insurance Company
January 5, 2017
Deegong Du30
Atty. DeegongDooterte
Cousel for First Integrated Bonding Insurance Company
AMS Compound, Davao City
Page 16 - Complaint