James Bond files a counter affidavit denying the charges against him from a traffic accident. He claims the following: (1) the traffic was congested and moving slowly when he gently accelerated into the rear of the vehicle in front of him that suddenly stopped, (2) he immediately took responsibility and offered to pay for repairs, and (3) despite multiple attempts to negotiate a settlement, the other driver declined and continued pursuing legal action. Bond maintains his innocence and willingness to resolve the matter outside of court.
James Bond files a counter affidavit denying the charges against him from a traffic accident. He claims the following: (1) the traffic was congested and moving slowly when he gently accelerated into the rear of the vehicle in front of him that suddenly stopped, (2) he immediately took responsibility and offered to pay for repairs, and (3) despite multiple attempts to negotiate a settlement, the other driver declined and continued pursuing legal action. Bond maintains his innocence and willingness to resolve the matter outside of court.
James Bond files a counter affidavit denying the charges against him from a traffic accident. He claims the following: (1) the traffic was congested and moving slowly when he gently accelerated into the rear of the vehicle in front of him that suddenly stopped, (2) he immediately took responsibility and offered to pay for repairs, and (3) despite multiple attempts to negotiate a settlement, the other driver declined and continued pursuing legal action. Bond maintains his innocence and willingness to resolve the matter outside of court.
James Bond files a counter affidavit denying the charges against him from a traffic accident. He claims the following: (1) the traffic was congested and moving slowly when he gently accelerated into the rear of the vehicle in front of him that suddenly stopped, (2) he immediately took responsibility and offered to pay for repairs, and (3) despite multiple attempts to negotiate a settlement, the other driver declined and continued pursuing legal action. Bond maintains his innocence and willingness to resolve the matter outside of court.
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COUNTER AFFIDAVIT
I, JAMES BOND, Filipino, of legal age, with address at
233, Zone 9, Patag, Manila City, after being sworn in accordance with law, do hereby depose and state:
1. That I am the accused in the above-captioned case
and the authorized driver of a Toyota Hilux with Plate No. AOE-257; 2. That I am innocent of the crime charged against me in the Affidavit of Complaint executed by Heinz Rudiger Heck, the private complainant herein; 3. That I was not reckless. In fact, I was very careful and employed all the necessary precautions during the whole incident; 4. That it was unfortunate that the said incident happened but it was purely accidental and without malice or bad faith on my part; 5. That I vehemently deny the allegation stated in paragraph “2” in the said complaint as it is false and fabricated. The truth of the matter are as follows:
a. That at around one (1) o’clock in the afternoon, on
February 20, 2018,, I was driving the above-described motor vehicle along Luna Street, Manila City, headed towards Lim Ket Kai Mall; b. That the traffic then was congested with the distance between cars was so close that they were almost touching each other; c. That when the traffic started to move, I gently stepped on the accelerator and slowly drove my motor vehicle forward; d. That a few seconds later, the motor vehicle in front of me, driven and owned by private complaint herein, suddenly stopped; e. That I immediately stepped on the brakes to avoid bumping into private complainant’s motor vehicle, however, I was already too late as I heard a thump coming from the front-right portion of my motor vehicle; f. That upon realizing that I accidentally bumped the rear portion of private complainant’s motor vehicle, I immediately went out of my said vehicle to check on private complainant and the damage I accidentally caused to his motor vehicle; g. That upon finding out that private complainant was unharmed, I felt relieved and I immediately expressed my intention to pay for the repairs of his motor vehicle; h. That I initially offered private complainant the amount of One Thousand Pesos (Php1,000.00) but he declined; i. That as alleged in paragraph “3” of private complainant’s Affidavit Complaint, two (2) RTA-Officers and a police officer arrived the incident to investigate;
6. That contrary to private complainant’s allegation in
paragraphs “7”, he was not ask to pay the balance of “P 1,800.00”. The truth is that FPG insurance was able to negotiate the amount from “P 6,800.00” down to “P 5,000.00”; 7. That it is likewise not true that I was not interested to settle this particular matter; 8. That since the day of the incident I have already expressed my intention to settle although it was declined by private complaint; 9. That sometime in March 2018 at the PNP Cogon Station 2, Manila, I offered to shoulder the expenses for the repairs of private complainant’s motor vehicle through FPG Insurance, the insurer of my motor vehicle. Unfortunately, we were not able reach an agreement as he was demanding an additional of “P500.00” per day for four (4) days for “Taxi-transportation”; 10. That after I was summoned by the City Prosecutor’s Office of Manila relevant to this instant case, I offered again to pay for the repairs including the additional “Taxi- transporation”. However, private complainant declined once more; 11. That sometime in August 9, 2018, I asked FPG Insurance to contact private complainant and settle this case yet the same still declined; 12. That at present, despite several failed negotiations, I am still willing to settle this case and avoid further litigations.
IN WITNESS WHEREOF, I have hereunto set my hand this ___
day of __________, in the City of Manila, Philippines.
JAMES BOND Affiant
SUBSCRIBED AND SWORN to before me this ___ day of
__________, in the City of Manila, Philippines, Affiant is known to me to be the same person executing this affidavit.