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Republic of the Philippines

National Capital Judicial Region


METROPOLITAN TRIAL COURT
Manila, Branch _____
ROBERT JAMES REID,
Plaintiff,

- versus -

Civil Case No. _________


FOR: Damages based quasi-delict

DANIEL PADILLA
Defendant
x--------------------------x
COMPLAINT
PLAINTIFF, through counsel, unto this Honorable Court most
respectfully alleges that:
1. Plaintiff is a Filipino Citizen, of legal age, married and with
residence at 2401 Taft Avenue, Manila, Philippines.
2. Defendant is a Filipino Citizen, of legal age, single, with
residence at 704 Rizal Avenue, Quiapo, Manila.
3. Plaintiff is the owner of the house located at 2401 Taft Avenue,
Manila Philippines. The Original Certificate of Title is attached
hereto as Annex A.
4. That on June 26, 2016, at eight (8) oclock in the evening, the
defendant was driving a privately owned vehicle, with a plate
number of ABC-123, which crashed into the plaintiffs house.
5. That as a result of the crash, the plaintiff was severely injured
causing his left leg and right arm to be amputated.
6. That the plaintiff incurred medical expenses for his injuries
resulting from the same incident in the amount of TWO
HUNDRED THOUSAND PESOS (P200,000.00) as evidenced
hereto by the medical receipt attached as Annex B.

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7. On June 26, 2016, the plaintiffs wife, Mrs. Nadine Lustre-Reid,


reported the incident to the police. A copy of the police report is
attached thereto as Annex C.
8. The total cost of repairs for plaintiffs house incurred a total of
ONE HUNDRED AND FIFTY THOUSAND PESOS
(P150,000.00) as evidenced hereto by the receipt attached as
Annex D.
9. That plaintiff, his wife, and his tender-aged children suffered
mental anguish, wounded feelings, and moral shock from the
incident.
10.
That as the cause of the incident, the plaintiff was not
able to go to work for six (6) months as a college professor to
provide for his family.
11.
That on July 5, 2016, a criminal charge case was
thereafter filed with the Municipal Trial Court of Manila charging
the defendant with reckless imprudence resulting in damage to
property with physical injuries.
12.
Likewise, the plaintiff reserved his rights to file for a
separate civil action against defendant.
13.
On July 15, 2016, the plaintiff, through a letter, demanded
from the defendant to pay for the cost of damage to the
plaintiffs house and the medical expenses incurred by the
plaintiff. As evidenced by Annex E.
14.
The plaintiff has not received any reply or payment from
the defendant.
15.
On August 15, 2016, a second demand letter was sent to
the defendant to pay for the cost of damage to the plaintiffs
house and the medical expenses incurred by the plaintiff. A
copy of which is attached hereto as Annex F.
16.
The plaintiff has not received any reply or payment from
the defendant.
PRAYER
WHEREFORE, in view of the foregoing, plaintiff prays that
judgment be rendered against defendant ordering him to:

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1. To pay plaintiff the amount of TWO HUNDRED THOUSAND


PESOS (P200,000.00) representing the medical expenses
incurred by the plaintiff.
2. To pay plaintiff the amount of ONE HUNDRED-FIFTY
THOUSAND PESOS (P150,000.00) by way of actual damages
as cost of repair to the damage done to the house of plaintiff.
3. To pay plaintiff the amount of THREE HUNDRED THOUSAND
PESOS (P300,000.00) representing loss of income.
4. To pay plaintiff THREE MILLION PESOS (P3,000,000.00)
representing loss of earning capacity.
5. To pay plaintiff the amount of FIVE HUNDRED THOUSAND
PESOS (P500,000.00) by way of moral damages.
6. To pay the cost of this suit.
CLASS-Z LAW FIRM
Counsel for Plaintiff
No. 81, West Capitol Drive
Bo. Kapitolyo, Pasig City
Tel No. (02) 562-8697 loc 45; +369178993397
classzlaw@classzfirm.com
By:
QUEENIE SABLADA
PTR No. 9833090 01-07-2014 Pasig City
IBP LRN 898982 05-09-2012 Pasig City.
MCLE Compliance No. IV0021523
July 30, 2013- Pasig City

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VERIFICATION AND CERTIFICATE OF NON-FORUM SHOPPING


I, Robert James Reid, of legal age, Filipino, Married, and a
resident of 2401 Taft Avenue, Manila, after having been duly sworn to
in accordance with law, hereby, depose and say:
1. That I am the Plaintiff in the above-entitled case and have caused
the preparation of the foregoing complaint to be prepared; that I read
and understood its contents which are true and correct of my own
personal knowledge and/or based on authentic records.
2. That I have not commenced any action of proceeding involving the
same issue in the Supreme Court, the Court of Appeals or any other
tribunal or agency; that to the best of my knowledge, no such action
or proceeding is pending in the Supreme Court, the Court of Appeals
or any tribunal or agency, and that, if I should learn thereafter that a
similar action or proceeding has been filed or is pending before these
courts of tribunal or agency, I undertake to report that the fact to the
Court within five (5) days therefrom.
IN WITNESS WHEREFOR, I have hereunto set my hand on this 27th
day of September, 2016.
James Reid
Affiant
SUBSCRIBED AND SWORN to before me this 27th day of
September, 2016 at No. 81 West Capitol Drive, Bo. Kapitolyo, Pasig
City.
Doc. No. 28;
Page No. 64;
Book No. 45;
Series of 2016.

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