REPUBLIC OF THE PHILIPPINES

Department of Interior and Local Government

BARANGAY PINSAO PROPER
BAGUIO CITY, PHILIPPINES

February 9, 2019

TO: HON. PEDRO DELA CRUZ

Punong Barangay

Mr. MARIO A. TORRES

Complainant,

- Against- For: Slight Physical Injuries

Mr. JUAN S. MIGUEL and

Mr. JUN S. MIGUEL

Respondents.
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COMPLAINT

COMPLAINANT respectfully state: That,

1. I, MARIO A. TORRES, 29 years of age, Filipino citizen,

single, is residing at No. 05 Tacay Road, Brgy. Pinsao Proper,
Baguio City.

2. The respondents are:

(a) JUAN S. MIGUEL, 27 years of age, Filipino, single and

with residence at No. 25 Stone Crusher, Brgy. Pinsao

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 Proper, Baguio City, Benguet, where summon may be
served;

(b) JUN S. MIGUEL, 22 years of age, Filipino, single and

with residence at No. 25 Stone Crusher, Brgy. Pinsao Proper,
Baguio City, Benguet, where summon may be served;

3. That the facts of the case are as follows:

(a) On or around 12 midnight of February 5, 2019, I was

walking in Zarate Village, located at Tacay Road,
Barangay Pinsao Proper, Baguio City, on my way home
from a birthday party. I was slightly inebriated due to the
beer I had drunk during the said party and was at first
unable to recognize the two men sitting at the side of the
street in front of the sari-sari store who were shouting
obscenities at me.

(b)Upon reaching a sari-sari store, Juan Miguel and Jun

Miguel, herein respondents, who were drinking began
throwing bottles of beer at me. A bottle hit me in the back
of my left leg, causing a superficial wound.

(c) Aling Nena Cruz, owner of the store, shouted at the two
respondents to stop causing them to leave the premises
and run to their house located at Stone Crusher,
Barangay Pinsao Proper.

(d) I continued my way home where my uncle Ramon

Torres saw the bleeding wound inflicted by the bottle.
My uncle drove and accompanied me to the Baguio
General Hospital for first aid.

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 (e) Dr. Dy Lim, the doctor who attended me disinfected and
covered the wound with gauze. He recommended a rest
period of nine (9) days.

(f) After the first aid was administered, my uncle and I went
to the Police Station 1 in Naguilian Road, Baguio City, to
report the incident.

(g)A copy of the medico legal certificate (Annex “A”), a

police blotter acquired from Police Station 1 in Naguilian
Road, Baguio City (Annex “B”), and the statement of a
witness (Annex “C”) are attached.

WHEREFORE, premises considered, it is respectfully prayed that

immediate summons be issued to respondents and that immediate
barangay conciliation/mediation meetings be held by the Barangay
Lupon. I also respectfully pray that respondents will be held liable
for actual, moral, and exemplary damages. The complainant
reserves the right to file the proper criminal actions against the
respondents Juan S. Miguel and Jun S. Miguel for the violations of
the Revised Penal Code.
Further, we pray for such and other reliefs as may be deemed just
and equitable in the premises.

MARIO R. TORRES
BIR TIN: 170-009-990-009
COMPLAINANT

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