REPUBLIC OF THE PHILIPPINES)
Province Of ____________________) S.S.
City/Municipality Of_____________
x------------------------------------------x
I, Roberto Nores, Filipino, 65, male, single, and a resident of 60 Pureza Street Sta. Mesa, Manila, Philippines, after being sworn to in accordance with law, depose and state:
Defendant Carles Nores, is my son residing at the same house at Pureza Street Sta. Mesa, Manila, Philippines;
That, at around 10:00 in the evening of October 29, 2012, after dinner, my son arrived at our house;
That, he saw my wife, Cecilia Nores in the kitchen washing the dishes, the kitchen being at least 5 feet from the dining table;
Without provocation, the defendant pulled a knife from the sink and proceeded to stab my wife with it.
That, upon seeing what my son did, rushed to my wife’s aid and called the hospital;
That, upon seeing that I was approaching he left immediately without even saying anything;
Upon calling for medical assistance and reaching the hospital, my wife was dead on arrival because of severe blood loss from the stabbing;
After attending to my wife, I reported the said incident to the nearest police station. A true and faithful machine copy of the police report is hereby attached here as “Annex A”;
I am therefore executing this Complaint-Affidavit against my son Carles Nores who may be served with subpoena and other processes of this Honorable Office at his residence at 60 Pureza Street, City of Manila, Philippines;
RELIEF
WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that, after hearing, judgment be rendered ordering the defendant:
To pay moral damages
To pay the plaintiff the cost of the suit;
Such other relief as the court may deem proper.
City of Manila, February 20, 2014.
FADERUGAO-FORTALEZA LAW OFFICE
Counsel for the Plaintiff
Unit 123, Victoria Tower I
Taft Avenue, Manila
By:
____________________________________
Roll of Attorney No. _____________
IBP No. _____________/______/______
PTR No. _____________/______/______
CERTIFICATION OF NON-FORUM SHOPPING
Republic of the Philippines)
Province of ____________________) S.S.
City/Municipality of _____________)
x - - - - - - - - - - - - - - - - - - - - - - - x
I, _____________, of legal age, Filipino, (single / married / widow), and a resident of _____________, Philippines, after being sworn in accordance with law, hereby depose and certify that:
I have not theretofore commenced any other action or proceeding or filed any claim involving the same issues or matter in any court, tribunal, or quasi-judicial agency and, to the best of my knowledge, no such action or proceeding is pending therein; (c) if I should thereafter learn that the same or similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or any other tribunal or quasi-judicial agency, I undertake to report such fact within five (5) days therefrom to the court or agency wherein the original pleading and sworn certification contemplated herein have been filed.
IN WITNESS WHEREOF, I have hereunto set my hand this _____________ at _____________, Philippines.
________________________________________________________
AFFIANT
SUBSCRIBED AND SWORN to before me, this _____________, by _____________ who exhibited to me (his/her) Community Tax Certificate No. _____________ issued at _____________, Philippines on _____________.
Notary Public
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of 20__;