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- versus -
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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