COMES NOW the plaintiff, by the undersigned counsel, and unto this Honorable Court, respectfully alleges:

      1. That plaintiff Michelle Cruz is of legal age, married and a resident of ______________; while the plaintiff Troy Moran is also of legal age, married and a resident of _____________________;

      2. That defendant XTC Corporation is a corporation duly organized under Philippine law, engaged in the business of manufacturing household appliances, with principal office at ________________, while the other defendant John Revilla is the driver of the corporation's delivery truck, and both may be served with summons at said address;

      3. That for cause of action against the defendants, it is hereby stated that on or about February 2, 1900, at about eight o'clock in the morning while driver John Revilla was driving the company's delivery truck, bearing plate No. WAR-234 along EDSA, within the territorial jurisdiction of Makati City, he so negligently and recklessly drove the delivery truck at a very fast speed in disregard of traffic conditions then existing that he caused it to bump with terrific force a Honda Civic sedan, bearing plate No. WRR-432, in which plaintiff were riding as passengers;

      4. That because of the terrific impact, the said Honda Civic sedan was considerably damaged not only in the rear portion but also in front or radiator portion, having been pushed several meters forward against other vehicles in front due to said strong impact;

      5. That because of the gross negligence of driver John Revilla, an employee of defendant XTC Corporation. the plaintiffs were thrown off balance, causing them especially plaintiff Michelle to bump her head and face against the front windshield of the car she was in, and causing contusions and bruises on her face, left earlobe and leg, as well as in other parts of her body;

      6. That by reason thereof, the plaintiff Michelle suffered not only physical injuries for which she was medically treated but also mental anguish, fright, serious anxiety and moral shock;

      7. That plaintiff Michelle had suffered actual damages for X-rays and medical assistance in a sum of P ________________________ and moral damages in a sum of P_________________;

      8. That plaintiff Troy Moran suffered physical injuries which did not require medical attendance, however, the Honda Civic sedan owned and driven by him was badly damaged and will require substantial repairs estimated to be P__________;

      9. That plaintiff Troy Moran, by reason of having been deprived of the use of his own car during the period of the repairs, estimated to be two (2) months, will be forced to take a taxi in going to and from his office in Makati at the rate of not less than P_______ a day, or an estimated actual damage of P_____________ for the duration of the repairs;

      10. That plaintiff Troy Moran, by reason also of having been deprived of the use of his private car, is missing important business contracts which will cause him loss of income to the extent of P________________for the duration of the repairs;

      11. That prior to the filing of this complaint, the plaintiffs through counsel, had written to defendant XTC Corporation that as employer of the defendant John Revilla, it is its legal obligation under the law to make good at least the actual damages suffered by the plaintiffs, but said employer ignored plaintiff's request for an extrajudicial settlement, such that the plaintiffs were compelled to go to court for redress of their grievances;

      12. That in being compelled to litigate, plaintiffs were obliged to engage the services of a lawyer who is entitled to attorney's fees in an amount of P______;

      WHEREFORE, plaintiffs through undersigned counsel, pray this Honorable Court, after due hearing, to adjudge defendants XTC Corporation and John Revilla, jointly and severally, to pay the following:

           (a) To Michelle Cruz:

                (1) Actual damages of P_______________

                (2) Moral damages of P_______________

                (3) Attorney's fees of P_______________

           (b) To Troy Moran:

                (1) Actual damages of P______________;

                (2) Loss of Income of P______________;

                (3) Attorney's fees of P______________;

      OR total damages for both plaintiffs in the sum of P_____________, with legal interest from the date of filing this suit, plus costs of the suit, and such other remedies as may be just and equitable in the premises.

      Malabon City, _________________, 2004.