Affidavit Complaint Serious Physical Injuries
Affidavit Complaint Serious Physical Injuries
Affidavit Complaint Serious Physical Injuries
Plaintiff,
PEDRO SANTOS,
Defendant.
x----------------------------------------------------x
AFFIDAVIT-COMPLAINT
COMES NOW, the plaintiff, by the undersigned counsel, and unto this
Honorable Court, respectfully alleges:
2. That the defendant’s son, Pedrolito Santos, who resided in 2nd street, Brgy.
Tubod, Iligan City, was caught in a buy-bust operation in January 31,
2020;
3. That the defendant, without having any proof, accused the plaintiff to be
the informant who gave the tip to the police officers which led to the
arrest of defendant’s son and thereby planned to retaliate against the
plaintiff;
4. That in the evening of February 1, 2020, while the plaintiff was walking on
his way home, the defendant who was holding a rock, suddenly appeared
and confronted him;
5. That the defendant shouted “Tungod nimu kay nadakpan akong anak!’;
6. That the defendant suddenly threw the victim to the ground and hit the
plaintiff repeatedly in his left eye with the stone he was holding;
7. That after hitting the plaintiff, blood oozed from his eyes and lower left
part of his forehead while shouting “Agay! Tabang!”;
8. That some of the bystanders and neighbors came to stop the commotion
and pulled away the defendant from the plaintiff;
9. That the plaintiff was immediately taken to the Gregorio Lluch hospital
where he was examined, treated and confined for 15days;
10. That due to the incident, the plaintiff suffered hemorrhage and
sustained several wounds in his head and forehead due to severe beating,
as evidenced by a medico-legal certificate provided by Doctor Willie
Ong, a copy of which is hereto attached as “Annex A”;
11. That said Doctor, in his opinion stated in the said medico-legal
certificate, said that the injuries sustained by the plaintiff will incapacitate
him for 30days and will need medical attention for the said span of time;
13. That due to the injuries inflicted by defendant against the plaintiff,
the latter was incapacitated to go to work for more than 30 consecutive
days resulting to the diminution of his salary as evidenced by a letter sent
by his manager Robina Gokongwei, a copy of which is hereto attached
as “Annex C”; and
RELIEF
SUBSCRIBED AND SWORN to before me, this 3rd day of March 2020.
The affiant, whom I identified through competent evidence of his identity,
personally signed the foregoing instrument before me and avowed under penalty
of law to the whole truth of the contents of said instrument.