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REPUBLIC OF THE PHILIPPINES

National Capital Region
REGIONAL TRIAL COURT
Manila, Branch 171

ANNE BERNADETH KALAW

Plaintiff,

-versus- CIVIL CASE NO. 0147-98

FOR DAMAGES

EMMANUEL NICASIO, and

GBII BUS CORPORATION
Defendant.
X-------------------------------X

COMPLAINT

PLAINTIFF thru counsel, and unto this Honorable Court, respectfully

manifests:

1. That plaintiff Anne Bernadeth Kalaw is of legal age, single, and

resides at no. 122 Cavite Street, Sta. Cruz Manila and within
the jurisdiction of the Honorable Court.

2. That defendant GBII Bus Corporation is a corporation duly

organized under Philippine laws, engaged in the business of
transporting passengers thru bus from SM North EDSA to
Quiapo Manila with principal office at #145 Claro M. Recto
Avenue, Manila.

3. That defendant driver Emmanuel Nicasio is employed by GBII

Bus Corporation as driver for GB Bus with plate no. AKN 994.

4. That on July 24, 2017, at about 9:30 pm plaintiff boarded at

defendants terminal GB Bus bearing plate no. AKN 994 bound
to SM North EDSA.

5. That approximately about 10:00 pm, while defendant driver was

operating and driving Bus bearing plate no. AKN 994 along
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Espaa Boulevard corner Maceda, Manila in a negligent and

reckless manner suddenly swerved from the outermost left lane
to the innermost right lane ignoring other ongoing vehicles, that
due to the swerving, the Bus sideswiped with another Bus
having plate no. WKN 786 driven by Raegan Cruz;

6. That herein plaintiff was seated at the side of the Bus from
which the impact was made, and due to the impact, plaintiffs
head hit hard on the side of the bus resulting to severe
traumatic brain injury;

7. That immediately after the incident, defendant driver tried to

escape from the scene, but was immediately apprehended by
PO1 Jose Reyes who was at that time in the middle of his
patrol with PO2 Juan Aquino.

8. That at about 10:10 pm An Ambulance came and delivered the

injured passengers including plaintiff to UST General Hospital
where plaintiff received medical treatment and was confined for
seven days.

9. That the total expenses suffered by the plaintiff for all the
medical treatments and prescribed medications amounted to
Php 410,098.00.

10. That herein plaintiff initially asked Defendant Corporation to

shoulder the medical expenses, but was outrightly refused.

PRAYER

WHEREFORE, IN VIEW OF THE FOREGOING, plaintiff through

counsel pray this Honorable Court, after due hearing, to adjudge
defendants GBII Bus Corporation., and Emmanuel Nicasio, jointly
and severally, to pay plaintiff the following:

1. Actual Damages for Medical expenses amounting to

410,098.00.
2. Attorneys fees amounting to 50,000.00.
3. Costs of suit.

All other reliefs which may be just and equitable under the
law are likewise prayed for.

Pasay City for Manila City, August 03, 2017.,

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GAII Law Office

Counsel for the Plaintiff
Suite 506 Don Santiago Bldg.,
1344Taft Ave., Pasay City
By:
Norfatimah F. Sunggod
IBP No. 789765 / 1-11-17
PTR No. 098192 / 1-18-17/Mla.
Roll no. 478092
MCLE No. 7812, April 2, 2017
Tel. no. 732-92-17

VERIFICATION AND CERTIFICATION

I, ANNE BERNADETH KALAW, of legal age, Filipino with

postal address at no. 122 Cavite Street, Sta. Cruz Manila, after
having been sworn in accordance with law, hereby depose and say
that:

1. I am the plaintiff above-entitled case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein
are true and correct of my personal knowledge and/or on the basis of
copies of documents and records in my possession;

4. I have not commenced any other action or proceeding

involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or
any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding

has been filed or is pending before the Supreme Court, the Court of
Appeals, or any other tribunal or agency, I undertake to report that
fact within five (5) days therefrom to this Honorable Court.

ANNE BERNADETH KALAW

Affiant
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SUBSCRIBED AND SWORN to before me this 22nd day of

August 2017, at Manila, Philippines, affiant exhibiting to me her CTC
No. 03861181 issued at Manila on August 1, 2016 and Passport No.
UU670597, thus satisfactorily having proven her identity to me.

KRIS EDRELLE R. BAGAOISAN

NOTARY PUBLIC
Commission expires: 31-12- 2017
PTR No.9276704, 1-12-16, Mla
IBP No. 38718, 1-12-16, Mla
Roll No. 21789
TIN No. _999-876-987-1_
Issued at: Manila, Philippines
Unit 112, ABC Tower, Ermita
Manila, Philippines
MCLE Compliance no. 222222

Doc No. ___;

Page No. _____;
Book No. ____;
Series of 2017
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