REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region

REGIONAL TRIAL COURT
BRANCH 76, QUEZON CITY

Spouses Tatay Ako and Nanay Ako,

plaintiffs,
- versus

Civil Case No. 0011

Tsu Per and Bus Abargas Lines, Inc.,

respondents.
x ------------------- x
COMPLAINT
COUNT I
PLAINTIFF, by counsel, respectfully states that:
1. Defendant, Bus Abargas Lines, Inc., is a company organized under the
Philippine Laws, operating a bus line from its principal office in 872 EDSA,
Cubao, Quezon City.
2. On or about February 1, 2016, defendant Tsu Per, a resident of #43 Jose
Rizal St. Mahabang-gubat, Quezon City, was operating a bus owned by
Defendant Bus Abargas Lines, Inc. as its agent, and was traveling in EDSA
going
to
Baclaran.
3. On or about February 1, 2016, Plaintiff Tatay Ako, while in the exercise of due
care, was operating his automobile on said route, also traveling in EDSA
going
to
Baclaran.
4. The vehicle owned by the Defendant Bus Abargas Lines, Inc. and operated
by the Defendant Tsu Per did negligently collide with and strike the rear of the
plaintiffs automobile on said date, damaging the latter.
5. Plaintiff Tatay Akos damages consist of:
a. Expenses for medical treatment and hospitalization
b. Future expenses for medical treatment
c. Loss of wages
d. Future loss of wages and earning capacity
e. Conscious pain and suffering
f. Future conscious pain and suffering
g. Permanent injuries to affected parts
h. Damage to his 2014 Porsche 911 Carrera

COUNT II
PLAINTIFF, by counsel, respectfully states that:
1. Paragraph 1 and Paragraph 2 of Count I are hereby incorporated as
Paragraph 1 and 2 of this Count II.

3. On or about February 1, 2016, Plaintiff Nanay Ako was a passenger in the

automobile of Plaintiff Tatay Ako, and which automobile was on said route,
EDSA going to Baclaran.
4. The vehicle owned by the Defendant Bus Abargas Lines, Inc. and operated
by Defendant Tsu Per did negligently collide with and strike the rear of the
Plaintiff Tatay Akos automobile on said date, damaging the Plaintiff Nanay
Ako.
5. Plaintiff Nanay Akos damages consist of:
a. Expenses for medical treatment and hospitalization
b. Future expenses for medical treatment
c. Loss of wages
d. Future loss of wages and earning capacity
e. Conscious pain and suffering
f. Future conscious pain and suffering
g. Permanent injuries to affected parts

WHEREFORE:
A. Plaintiff Tatay Ako demands judgement against the Defendants, jointly or
severally as the law allows, in the amount of P20,000,000, with legal interest, for
the ACTUAL DAMAGES mentioned in Count I (5) and P50,000 for attorneys
fees.
B. Plaintiff Tatay Ako demands judgement against the Defendants, jointly or
severally as the law allows, in the amount of P10,000,000, with legal interest, for
the ACTUAL DAMAGES mentioned in Count II (5) and P50,000 for attorneys
fees.
Other just and equitable reliefs are also prayed for.
Quezon City; February 7, 2016.

(Sgd.) ATTY. DEE PAPATALO

Attorney for Plaintiffs
DEE PAPATALO LAW OFFICE
142 Brgy. Laging Panalo
Quezon City, Philippines
Roll No. 124353
P.T.R. No. 1234567 / Quezon City / January 10, 2016
IBP No. 409601 / Quezon City / January 20, 2016
MCLE Compliance No. V-0012891 / Quezon City / December 12, 2015

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, Tatay Ako, of legal age, do hereby state that: I caused this complaint to be
prepared; I have read its contents and affirm that they are true and correct to the best of
my own personal knowledge; I hereby certify that there is no other case commenced or
pending before any court involving the same parties and the same issue and that,
should I learn of such a case, I shall notify the court within five (5) days from my notice.

IN WITNESS WHEREOF, I have signed this instrument on February 10, 2016.

(Sgd.) Tatay Ako

SUBSCRIBED AND SWORN TO before me in Quezon City on this day of

February 7, 2016, affiant exhibiting before me his community tax certificate no.
CC493810 issued on January 31, 2016 at Quezon City.

Sgd. N. O. Tario
Notary Public
Until December 31, 2016
PTR No. 525253 / 01.10.16
Issued at Quezon City
On January 31, 2016

Doc. No.
Page No.
Book No.
Series of 2016.