REPUBLIC OF THE PHILIPPINES )

MUNICIPALITY OF _________ ) S.S.

PROVINCE OF LA UNION )

AFFIDAVIT

I, MANUEL REY B. LITTAUA, of legal age, single, Filipino citizen, and

a resident of and with postal address at 5 Poblacion, Bacnotan, La Union, after
having been duly sworn to an oath in accordance with law, do hereby depose
and state:

1. That on August 12, 2018 at 11:45 o’clock in the morning I was on

board our family’s Toyota Hi Ace GL which was being driven by Aaron
Ivan Aguila, the accused and a contractual driver of our family. At the
time of the incident, we were traversing the national highway along
Brgy. Urayong, Caba, La Union, when the car in front of us, a Honda
City bearing plate no. NFI774 driven by one Peter Soriano
suddenly/momentarily stopped which caused our driver to apply the
car brakes in a calculated manner as he did not want to hit the brakes
with one immediate stop because he did not want the car to skid and
lose control since the road was then very slippery due to heavy
downpour at the time, which case would result to more damage to our
car and that of the other car;

2. That the cause of the collision between the car I was riding was the
sudden/momentary stopping of the car in front of us (Honda City
bearing plate no. NFI774);

3. That during the collision incident, there was a heavy downpour which
rendered the road very slippery and our driver was driving at a very
calculated slow speed of 40 kph and maintained our lane all throughout
until the collision incident;

4. That the car I was riding then driven by the accused is about 2 vehicles
distance from the front car (Honda City) involved in the collision
incident;
Affidavit of Witness for the Accused Page 1 of 3

Re: Criminal Case No. 4833 for Reckless Imprudence Resulting

in Damage to Property
 5. That at the time the car in front of us suddenly stopped, the driver of the
car I was driving applied his brake properly (in a calculated manner)
and promptly to slow down and prevent colliding with the car in front of
us;

6. That the suddenness of the stop by the front car gave our car very little
time to react with the brakes applied and considering that the road was
very slippery caused by the heavy downpour at the time;

7. That the car in front of us stopped so suddenly and without any signal
light engaged to warn/advise driver of the vehicle behind it as to its
driver’s intended next action (e.g. if it will make a turn to the left or
right); and that during the investigation at the police station in Caba, La
Union, the driver of Honda City car, Peter Soriano told the investigator
that the engine of the Honda City went off that caused it to
suddenly/momentarily stop, and as a consequence, the car I was riding
that was behind the Honda City car collided with the Honda City in
front, hitting its rear bumper and caused damage (dent) on its trunk.

8. That the two (2) vehicles distance between the car I was riding was a
safe distance under the circumstances presenting at the time but because
of the suddenness of the stop made by the car in front of us, our driver
could not make the immediate stop for fear of skidding to prevent the
collision considering the slippery road condition that day;

9. That the driver of the car I was riding then made efforts to prevent the
collision by applying the brakes in calculated manner to prevent the car
from skidding if he applies a sudden brake, which case would probably
result to greater damage to both our car and the car in front of us or
even would result to injuries to passengers of both cars;

10. The resulting damage to both cars will support the prudent and diligent
effort made by our driver under the circumstances presenting at the time
in trying to control the car and to prevent the collision; that the front car
only sustained minor damage to its car’s rear bumper and baggage
compartment (trunk), as with our car which also suffered from minor
dents on its front bumper and parts;

Affidavit of Witness for the Accused Page 2 of 3

Re: Criminal Case No. 4833 for Reckless Imprudence Resulting

in Damage to Property
 I am executing this Affidavit to attest to the truthfulness and veracity of the
foregoing and for all legal intents and purposes it may serve.
]

IN WITNESS WHEREOF, I have hereunto set my signature this ___ day

of __________________, 2018 at __________, La Union.

___________________________
Affiant

SUBSCRIBED AND SWORN TO before me this ____day of

_______________, 2018 at _________________________. Affiant exhibited
to me his ________________________________ and confirmed that he
executed the foregoing Affidavit voluntarily and of his own free will.

___________________________
Notary Public

Affidavit of Witness for the Accused Page 3 of 3

Re: Criminal Case No. 4833 for Reckless Imprudence Resulting

in Damage to Property